ML20059H043

Insp Repts 50-327/90-23 & 50-328/90-23 on 900625-29.No Violations or Deviations Noted.Weaknesses in Program Implementation Noted.Major Areas Inspected:Plant Program to Maintain Occupational Dose to Workers ALARA

ML20059H043
Person / Time
Site:	Sequoyah
Issue date:	08/21/1990
From:	Gloersen W, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059H033	List: ML20059H031 ML20059H043
References
50-327-90-23, 50-328-90-23, NUDOCS 9009140202
Download: ML20059H043 (12)

See also: IR 05000327/1990023

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UNITED STATES

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NUCLEAR REGULATORY COMMIS$10N

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REGION 11

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101 MARIETT A STRE ET, N.W.

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ATLANTA,GEDR3tA 30323 '

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M)6 3 01990

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Report Nos.: 50-327/90-23 and 50-328/90-23

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Licensee: Tennessee Valley Authority

6N38a lookout Place

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1101 Market Street'

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Cnattanooga, TN 37402-2801

Docket Nos.: 50-327 a".1 50-326

Licensee Nos.:

DPR-77 and DPR-79

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Facility Name: Sequoyah I and 2

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Inspection Conducte .

Ju e'25-29, 1990

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Inspecto :

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Fat ' Signed

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Approved by:

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d(P. . Potter,' ChWf

Uate' Signed

Facilities kediation Protection Section -

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Emergency Preparedness and Radiological

Protection Branch

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Division of Radiation Safety and Safeguards

SUMMARY

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Scope:

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This routine, unannounced inspecthn of radiation protection activities focused

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on the plant program to maintain occupational! dose to workers as low as

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reasonably achievable (ALARA).

Results:

No violations or deviations were identified. . All elements.necessary for an.

adequate ALARA program were in place.

However, there were weaknesses in

program implementation in the following areas:

accountability for. collective -

dose by department managers (Paragraphs 2.b and c); establishment of collective

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dose goals and management of collective dose (Paragraph 2.d); implementation of-

a comprehensive source term reduction program; at Sequoyah--(Paragraph 2.h).-

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reduction of contaminated areas of the plant (Paragraph 2.1); . awareness

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training for plant staff and radiological impact evaluators and implementation-

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of an ALARA standard for the station (Paragraphs 2.j and k). : Based on the

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telephone conversation discussed in Paragraph 3, the NRC, Region II-under_ stands

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that Sequoyah is taking action on several of these matters.

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9009140202 900830

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PDR

ADOCK 05000327

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REPORT DETAILS

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1.

Persons Contacted

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Licensee Employees

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• R. Beecken, Manager, Maintenance

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• H. Burrynski, Manager Site Licensing

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J. Bynum, Vice President, Nuclear Power Production

• W. Byrd, Manager, Project Controls & Financial Services

• R. Daniels Engineer, Nuclear Engineering

• G. Fiser, Superintendent, Chemistry and Environmental

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• S. Holdefer, Health Fhysicist,' Radiological Controls

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• G. Hudson, Corporate Manager, Radiological Controls

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• M. Lorek, Superintendent. Operations

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• J. Osborne, Health Physicist, Radiological Controls

• J. Proffitt, Acting Manager, Compliance Licensing

• W. Smith, Specialist, Quality Assurance

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• M. Sullivan, Superintendent, Radiological Controls

• P. Trudel, Project Engineer, Nuclear Engineering

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• C. Vondra, Plant Manager

• C. Whittemore, Engineer, Licensing

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Other licensee employees contacted during this' inspection included

craf tsnan, engineers, mechanics, technicians, and adn.inistrative

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personnel.

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Nuclear Regulatory Connission

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• P. Harmon, Senior Resident Inspector

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• D. Loveless, Resident Inspector

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• Attended exit interview

2.

MaintainingOccupational-ExposuresALARA(83728)

10 CFR 19.12, states, in part, that all individuals working in or

frequenting any portion of a restricted area; shall -be instructed in

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precautions or procedures to minimize exposure.

10CFR20.1(c) states,inpart.thatpersonsengagedinactivitiesunder

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licenses issued by the NRC should, in addition to complying with the

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requirements set forth in this part, make every reasonable effort to

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maintain radiation exposures, as low as reasonably achievable (ALARA). .

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Other recontended elements of an ALARA program are contained in Regulatory

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Guides 8.8 and 8.10.

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The following are observations that the inspectors made during the

inspection. The observations were idcntified for licensee consideration.

for program improvement, but have no specific regula*;ory requirement.

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a.

ALARA Program

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The station's ALARA program was controlled by three administrative

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procedures, ALARA Planning, Site ALARA Connittee, . and ' ALARA

Suggestion Procram.

These procedures described personnel functions

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and responsibilities for the program and name the Site Director as

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having the ultimate onsite authority and responsibility for its-

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implementation. The Superintendent of Radiological Controls (RADCON)

advised the Plant Manager and supervisors regarding dose reduction,.

and plant supervision was responsible for implerrenting procedures to

reduce collective dese.

In addition, first .line supervision was

responsibic to actively pursue' and encourage the subniittal of ALARA .

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suggestions, and each individual was to be cognizant of, and work to

minimize, his or her dose.

b.

Dose Accountability

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The inspectors reviewed the licensee's method to account for the

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station's collective dose.

The review included an examination of

selected ALARA pre-job and post-job reviews and discussions with

licensee representatives.

It was observed that for the Unit 1. (UI,

C4) refueling outage, approximstely 90 percent of the station's

collective dose (893 person-rem out of g8? person-rem accumulated)

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underwent an ALARA review.

On the average, the licensee had been

performing ALARA reviews for. approximately 85' percent of the

station's collective dose.

The licensee had an adequate program for

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dose accountability although, as .noted. . in Paragraph 2.c of this.

report department management was not always utilizing the information,

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All jobs whose estimated collective dose was greater than l' man-rem

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received an ALARA review by the radiological controls group.

Jobs

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whose estimate was greater than five person-rem went to the ALARA

Comittee for review.

Job history files which were used during the

review process, were maintained by the radiological l controls group.

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The _ inspectors also reviewed radiologicalt incident reports (RIP,s)

covering the period from January to June 1990, and observed that

there were no significant ALARA program weaknesses or trends

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identified. One RIR identified an isolated event in which a group of

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resistance temperature detector (RTD) modification' fitters removed.

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insulation 'and lead shielding without proper health. physics (HP)

coverage. The licensee took inrediate corrective action and escorted

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the fitters from the work area and analyzed their personnel

dosimeters.

There were no individual doses which exceeded the-

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administrative limits.

The long term corrective actions included

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retraining on RWP requirenents, a review of the event, and a review

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on the proper method to notify HP.

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During this inspection, interviews with several departmental n.anagers

cn ALARA awareness and accountability were conducted.

The licensee

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had identified that it was not clear that line n.anagement was held

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accounttble for radiological dose performance goals.

Licensee

representatives indicated that in response to this finding, inclusion

of departnental collective dose performance e als in departnental

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managers' performance appraisals would be evaluated and considered.

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c.

Dose Management

The inspectors interviewed several departmental managers, reviewed

managsment tools used to. track. collective dose, and reviewed the

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departmental collective dose perfonnance against the dose allotnent.

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Theinspectorsdiscussedwithlicenseemantgersandsupervisorsthe

utility s ALARA program, including their knowledge of ALARA goals,

concepts, policies - and procedures

individual responsibilities,

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personnel exposure, and dose limits.

Additionally, the discussions-

included managers' cons.unication with co-workers and supervisors,

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participation in the ALARA suggestion program, the n.anagers'

perspective on how to iniprove the ALARA program, what events have

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caused increased personnel dose, and what events or conditions have

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helped reduce personnel radiation doses.

The: inspectors interviewed

n.anagers or supervisors from the following departments: maintenance,

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nuclear engineering, operations, technical support, and steam

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generator maintenance.

Each individual interviewed was generally

familiar with' the basic ALARA concepts. - Additionally. -individuals

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interviewed knew that they had a- basic responsibility for-

implementing the utility's ALARA program by performing tasks in a

manner- consistent with the utility's ALARA- policy.

Although it

appeared that u.anagers were aware of departmental dose goals, only

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one of the n.anagers interviewed knew his numerical departnental

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collective dose goal.

'Similarly, only one of the managers

intin!iewed knew the current accumulated collective dose for his

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department.

Mr.nagere generally understood where the ALARA

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requirements originated and what utility docun.ents described the

ALARA program objectives.

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The inspectors also reviewed the licensee's department collective

dose performance against the various departnental goals.

Each

department except the Operations Department had exceeded its fiscal

year (FY)1990dosegoal. The data are sunenarized below:

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Departrent

FY 90 Goal

FY 90 Actual

(person-rem)

(person-rem)

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Maintenance

209

269

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Modifications

200

418

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Technical Support Services

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13

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Radiological Control

100 ,

111

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Quality Assurance

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Operations

30

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Nuclear Engineering

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57

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Steam Generator

65

139

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Other

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As will be discussed in Paragraph 2.d. of this report, the higher

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than projected collective dose was due to the work scope of the

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outage including RTD bypass renioval

UHI removal, steam generato.

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nozzle dem installation, and reactor coolant pump modifications.

The inspectors also reviewed the licensee's pethods for tracking

collective dose for effective. dose managenient.

It was observed that

the licensee had a good program for accessing the data base:to track

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individual dose, departmental collective dose, and job collective

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dose. These data were easily displayed numerically or in the form of

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charts and graphs that could easily be used by. the departniental

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manager to track, trend, and manage their dose allotment.- Through

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discussions with the licensee, it was noted that-during the. last

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outage only the Maintenance Departn.ent received collective dose trend

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charts.

Although the information was available, the other

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departnients had not requested nor had . they been provided the

collective dose summary information in order to aid in n.anaging their

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departmental dose allotment.

d.

Collective Dose Goal

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The inspectors reviewed the licensee's procedures and methods used to

establish the collective annual dose goal.

Based on a review of

data, procedures, and interviews with managers and ALARA group

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personnel, the inspectors noted that the site annual collective dose

goalwasbasedonworkscopefortheyearandwasinitially(developed

by the ALARA Cemittee.

The Radiological Controls Group Radcon)-

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forwarded to each department head the anticipated work scope for the'

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year and dose rates expected.

The department section heads provided

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the number of man-heurs and developed their FY dose estin.ates for

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subn.ittal to the ALARA Conmiittee for approval. After a review by the

ALARA Conuittee, the annual collective dose goal' approval chain was

the Plant Manager, Site Director, Vice President Nuclear Power

Production, and Vice President Nuclear Power..

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In mid-1989, Radeon collected department inputs for FY 1990 and

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submitted 912 persen-rem to the ALARA Comittee for approval.

On

October 13,1pCS, the ALARA Comittee sut" ited the estimate to the

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Site Director. The initial estimate was disapproved, and the goal was-

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established at CBS person-rem.

The goal of 685 person-rem was

exceeded in' April of 1990 due to 6dditional work sco>e, .an escalated

schedule, and weaknesses that are. discussed in deta'l later in the

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inspection report.'

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In June 1990, the superintendent of Radcon submitted a change request

for a new annual ~ collective dose goal of 1,365 person-rem.

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justification for the amended goal was that work scope changes had

not been icehtified during the initial goal developnent, and a shift

of 20 days of the Unit 2, Cycle 4 outage into FY 1990 (20 days of

U2, C4 outage are expected to result;in as much as 350 person-rem).

In addition. -durin0 this FY 1990 goal development process, site.

rnanagement reduced the site goal to below what was in the goal basis.

The justificetion for the change was submitted on June 15, 1990, from

the V. P. Nuclear Power Production to the Senior V. P. Nuclear Power

and was rejected.

During this inspection, the Radcon ALARA group was in the process of

preparing a justification' for another change to . establish the

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collective dose-goal at 1,035 >erson-rem., The' inspectors noted that

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currently the site collective cose was at 1,075 person-rem, and three

months remained in FY 1990.

After interviews with key department managers and plant managenent'

(Paragraph 2.c), the inspectors noted that< the parties associated

with establishing an annual site collective dose goal did not appear

+o be comunicating well; that the current effort underway, if

approved, would not result in a realistic goal since it had been

surpassed;-and that the licensee was not effectively using the goal

process as one of the managenent tools to control collective dose at

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the station.

The inspectors noted the recomendations in Regulatory

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Guide 8.8 that meeting appropriate ALARA goals and objectives

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provided measures of ALARA program effectiveness.

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During the exit meeting, the Plant Manager stated that a realistic

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collective dose goal would be developed for the remainder of FY 1990,

c.

ALARA Reviews

Licensee procedure requires that. pre-job ALARA reviews be performed

for. all jobs in which the collective dose was expected to exceed

I rerson-rem or where radiation dose rates exceed I rem per hour.

/11so, for jobs expected to result in collective dose greater than

5 person-ren, an ALARA Comittee review was required. The inspectors

selectively evaluated prc-job ALARA reviews performed in 1990.s and

verified that appropriate dose reduction techniques and lessons

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learned from previous similar work were considered in the reviews. To

aid workers in reducing dose, dose reduction techniques and

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were listed on an addendum

requirements developed by the ALARA group (RKP) and'went to the field

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to the applicable radiation work permit

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as'sp cial instructions with the RWP.

The inspectors requested post-job ALARA reviews for 12 of the U1,

C4 outage high dose jobs.-

Radeon was still working with other

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department personnel on the post-job debriefings and provided six

completed post-job reviews.

Based on an evaluation of the post-job-

reviews and discussions with plant personnel, the inspectors

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determined that problems occurred during the outage that resulted in

higher than anticipated dose to workers. The following are the more

significant problems: -(a) non-critical path work was performed in

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containment when the reactor coolant- system (RCS) water level was .

drained for RTD bypass removal; the loss of water shielding resulted.

in an increase in radiation levels of 200-300 percent. . Dose cost was

46 person-rem; (b) minimal amounts of temporary lead shielding were

used due to unavailability, delays, schedule, and seismic restraints;

( 'e cost was 15 person-rem;-(c) poorly traintd and or inexperienced

> ;ers; dose cost 11 person-rem; (d) overcrowding,in work areas .and

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large use of respirators due to. high levels of. loose surface

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.ntamination; dose cost unquantifiable.

The_insSectors noted that

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the licensee had purchased additional temporary s11elding and other.

problems identified in the post-job debriefings were placed.on an

action item list to be resolved prior to the upcoming Unit 2 outage.

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The inspectors reviewed dose estimates for 55 jobs that included RWP

hours and dose rate information.

The following sunnary shows -the

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estimated versus actual performance:

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Percent of.

Estimated

Actual

Estimate

Number of people

3,603

7,460

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RWP hours

103,238

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Whole Body Dose

694.366

893,018

129

(person-millirem)

Whole Body Dose Rate

6.72

7.27

116

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(person-millirem /hr)

The inspectors concluded that the process for estin.ating doses for

jobs was good for the majority of jobs and that the post-job reviews

were identifying significant problems, that when corrected, would

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improve dose control.

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ALARA Consnittee

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The inspectors reviewed and discussed - with cognizant licensee

representatives the current: ALARA Connittee organization and its

functional responsibilities.

Details regarding the Connittee

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organization and functions were_ outlined. in SQA-209, " Site ALARA

Comittee," Revision 1 dated April 9,1990. The Comittee consisted

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of at least one representative each from radiological controls,

maintenance, operations, modifications, site OA, and nuclear

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engineering whose attendance was required for a quorum.

Representatives from:the corporate. office were normally invited. .

The Connittee reviewed ercas of potential exposure in the plant:to-

determine mechanisms to reduce doses and to review dose saving

suggestions for viability.

The Chairman of the Comittee was

nonna11y the= Maintenance Penager; however, this responsibility ~ was

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recently being shared with the Plant Manager.

By procedure, the ALARA Comittee was required to meet quarterly;.

however,- during the outage period the Comittee would reet nore

. frequently, typically. weekly to tronthly.

Af ter reviewing Comittee

meetino . attendance records for 1990, the inspectors noted two

cancelled neetings due to lack of attendance.

The inspectors

reviewed the topics discussed during the ALARA Comf , tee neetings

which mainly consisted of review and approval of high dose jobs and a

review of ALARA suggestions.

Recently, the threshol . for requiring'

the site ALARA Comittee to review and. approve work Das reduced from-

10 to 5 person-rem.

Additionally, the site ALARA Comittee was

recently given the responsibility to review containment power entries

and establish designated containment power entry days for scheduling

and coordinating work.

Also, the site ALARA Comittee was. tasked

with performing quarterly reviews of departmental and station dose

goal performance and making recomendations and : adjustments .when

necessary.

The licensee's ALARA suggestion program was effective, with 'several

dose savings suggestions implenented.

In 1989,.33 ALARA suggestions

were submitted, and eight were being implemented to dete.

In 1990,

14 suggestions were submitted, and two were being implerented.

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licensee's incentive program has resulted in individuals submitting

viable suggestions.

An liLARA subcomittee prereviews_~ all ALARA

suggestions and submits the best ones to the : ALARA Comittee for

consideration,

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Dose Reduction Initiative

The inspectors discussed with licensee representatives. from both the

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station and the corporate office, several dose reduction initiatives

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which have been implemented.

It was noted that the licensee had

implemented an induced crudburst control and cleanup program at the

station.

The program allowed the. licensee to control when a

crudburst would occur by adding hydrogen peroxide to' the primary

coolant system and removing the activated crud using the ion exchange

purification system. This-program helped the licensee lower the dose

rates and contamination levels in the primary system and irtprove-

water clerity for refueling operations.

During the U1, C4 outage,

hydrogen peroxide was added to the primary coolant with the system

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con.pletely full which maximized the Co-60 removal due to the

increased letdown ficw rate and circulation 'in .the' loops.

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licensee had also undertaken several other dose reduction projects.

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The following dose reduction initiatives were either completed or

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scheduled:

Reactor head instrument port conoseal c1kmp replacement

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RTD menifold removal (U1 con.pleted; U2 scheduled for FF4),duled

Upper head injection system removal (U1 completed; U2 sche

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Laser videodisc and photographic display system (U1' completed;

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U2 scheduled for RF4)

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Reactor coolant pun.p cartridge-type seal nodification (two RCPs-

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per unit remaining for modification)

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Modification on steam generator nozzle dam.s to reduce time for

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installation in steam generator channel head (Unit I completed;

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Unit 2scheduledforRF4)

Additionally, the inspectors' noted that.the licensee was considerin

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the acquisition of a permanent reactor-head shield to reduce genera

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area dose rates during fuel movement.

Acquisition of a head shield

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was slated for the Fall of 1991.

The inspectors also discussed with licensee representatives the use

of temporary shielding during the U1', C4 outage.

It was determined

that several scheduling constraints and seismic concerns precluded

shielding crews from installing some shielding near the RTD manifolds

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which resulted in- higher doses for- crews performing S/G sludge-

lancing operations.

Another contributing problem was a lack of lead

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shielding.

The inspectors discussed with representatives from the.

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corporate office and the station the use of standard load tables for

adding temporary shielding to piping and various components to aid in

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reducing the amount of time for approval and installation of

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temporary shielding during outage critical path periods,

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Source Term Reduction Initiatives

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The inspectors discussed with licensee representatives from the

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station and corporate office methodsi for reducing out-of-core

radiation sources ' which would offer -the greatest potential for

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continued reductions in occupational radiation dose.

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techniques

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cobalt . source

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preconditioning of out-of-core surfaces, control of crud transport,.

and chemical decontamination.

Earlier this year, the licensee's corporate office had identified the

need-to formulate a concerted source term reduction program.for TVA.

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The corporate chemistry department initiated a plan to formulate

connittees to address source term reduction initiatives such as:

stellite control, system preconditioning, chemical decontamination,

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and elevated reactor coolant pH.

The licensee's_ Watts Bar= facility

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had comitted the resources to help develop and implement the source

term reduction initiatives.

With site-specific cdjustments, the licensee's corporate office

planned to apply the source term reduction initiatives at the other

TVA facilities.

As of this inspection, the licensee's source term

reduction plan was still in the developmental stages; consequently a

site-specific plan for the Sequoyah facility had not been addressed..

HowcVer, as noted in Paragraph 2.g, the licensee's Sequoyah facility

has taken the initiative to reduce future occupational collective

rediation dose by component removal, such as the RTD bypass manifolds

'and the upper head injection system on Unit-1, and hydrogen peroxide-

cddition at shutdown.

The inspectors noted that there was no

schedule for application of the Watts Bar initiatives at the Sequoyah

facility.

1.

Contaminathn Controls

The inspectors reviewed the licensee's program to control

contaniination at the source.

The inspectors noted the licensee had

exceeded the goal of 240 personnel contamination events (PCEs) by 12

at the end of June.

Licensee personnel stated that, although six

weeks of the Unit.2 outage is scheduled for this FY, they felt that

PCEs will be lower than the pre.vious two years of 409 in 1988 . and

435 in 1989.

During tours of the radiologically controlled area (RCA)- of: the

plant, the inspectors observed that large areas were being controlled

as contaminated after the outage.- Based on licensee data, the total

RCA was 228,940 square feet (ftr) of which 8,200 fte of reclaimable

and 17,200 ft2 of non-reclaimable area existed prior to the U1, C4 -

outage.

During the inspection the - licensee was maintaining

13,612 fte as reclainable and 17,000 fte as non-reclaimable

contaminated area for a total of 30, 612 ftr. : The -inspectors

determined that a significant cmount of non-reclaimable area at

Sequoyah was normally considered reclaimable at other utilities. The

inspectors interview d licensee personnel and learned that the higher

priorities. may have prevented engineering approval to- place pump

shaft guards on pumps in radioactive systems.

Such guards would help

contain contan.ination.

Consequently pun.ps with radioactive leaks

resulted in whole rooms being contaniinated rather than just the pump

bed.

Licensee personnel stated that at the end of the outage the intent

was to reclaim areas that became contaminated during the outage, but

resources to acconiplish - this were eliminated.

Also, licensee

representatives stated that durin

resources (training and staffing) g both normal and outage periods

were limited in comparison to the

task.

The inspectors discussed this issue with plant management and

were- inforned that the engineering problem regarding approval for

containnents would be given inmediate attention 'and that for . Unit 2

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outage personnel would be inade available for' decontamination work.

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Licensee managenent stated that it was their goal to reclaim

contandnated areas during the titre between obtages 50 that the total

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contendnated area would be the s6ne going into the next outage as

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there was going into the past outage.

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ALARA Training

The inspectors toured the Plant Op(erations Training Center and

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reviewed general erployee training GET) lesson plans.

1he lesson

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plans appeared to be well developed as were the instructor teaching

aids.

Based on interviews with instructors and plant. personnel, the

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inspectors learned that, other than GET, plant personnel did not'

receive additicr.61 classroom training in ALARA concepts, techniques,

or practical factors. The licensee, in the past year, had eliminated

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from the station's curriculum ALARA Awareness training and' Advanced

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Radiation Worker training. - In addition. the number of instructors-

providing the training had been cut back.

ALARA Committee neeting

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minutes 90-18. June 15,1990, recorded that employee exit interviews

revealed a number of concerns relating to dose reduction. The ALARA

Comittee, in seeking a resolution to this item, had requested that

GET be reviewed for ALARA content.

The inspectors ' concluded that

although training tret the requirements of -10 CFR 19.12, there had

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been reductions in that area of training that had been intended to

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result in better worker dose control.

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Audit Program

1

The inspectors reviewed audit reports perforrned by the fluclear

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Quality Audit and Evaluation- (NOA&E) group and surveillances

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performed by Quality Assurance Organizations for radiological

controls.

In general the eudits and surveillances were indepth and

substantive.

NQA&E audit Report ho. SQA 89002, dated January 9,

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1990, focused on ALARA and radiological effluent monitoring.

Overall, the audit found that the ALARA program was adequate- and-

cffective, and cited a number of strengths.

However, a condition

adverse. to quality was found regarding the failure to implement an

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ALARA standard.

In discussions with' ALARA group- personnel, the

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inspectors learned that the need for an ALARA standard was identified

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by the corporate office and that Nuclear Engineering (NE) had three:

design guides for use for ALARA reviews. These design guides had not

been formalized into the program,- DesignChanceNotices(DCNs)were

routed to Radcon engineers f 'a courtesy. and that Radcon had a

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backlog of up to six months between receipt and complation.

This

delay. in corrpletion was-attributed to the reduced level of'the ALARA

3

staff and an increase in DCNs.-

In managerrent . interviews. the

Chairman.of the ALARA Comittee stated that a large number of DCNs

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were issued during the outage and that it impactec the work of the

' ALARA Connittee.

The inspectors reviewed thc change to Radcon

Instruction 10, Implenenting ALARA- for - Radiaticn Exposure and -

Radiological Environnental Imptets" and noted that the standard was

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approved.

However, it was not approved for in.pleneentation by NE due

to lack of staffing resources.

The new change implementing the

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standard would - require that radiological impact evalut,tions be

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conducted for most site radiological work. The standard also requires

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that ALARA Awareness training be given to all NE radiological in. pact

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evaluators.

The inspectors noted that the standard was approved by

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the station en July 17

1969, but had not been implenented in the

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- past year,

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The inspectors in reviewing surveillances of the radcon' program noted

a significant number of worker radiological knowledge problems were

identified as well as compliance problems.

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The inspectors determined that the audits and ~ surveillances were ;

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generally indepth and docunented substantive prcblems that were being

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addressed by the licensee.

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3.

Exit Interview

The inspection scope and- findings were supinarized on June 29, 1990, with

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-those persons indicated in Paragraph 1.

The items discussed are outlined

,

in the sunnary to this report.

Licensee management stated that it was

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their position that the station.was operating the ALARA program with a

realistic collective dose ' goal.

The licensee stated that it was their

intent to fully account for the collective dose for the remainder of -

FY 1990; however, the licensee was not able to offer a specific number for

the collective dose goal.

The licensee made an oral- commitment. to

establish a realistic annual collective dose goal for the remainder of

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FY 19M. On July 30, 1990, D. Collins ,-' B. Wilson - J. ' Brady. . R. Shortridge :

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of Reglon II NRC and C. Vondra, C. Kent, and C. Whittemore of Sequoyah

Nuclear plant participated in a telephone : conversation relating to the

1

weaknesses identified in the report and actions that are being taken by

,

the licensee to resolve the weaknesses. . During the- telephone conversation,

the licensee outlined the following- insnediate actions: ' (1) the licensee

'

has established a monthly collective dose goal and will manage collective

dose using this as e management tool-through FY 1990; (2) Sequoyah has

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formally established a task force to develcp a comprehensive source term

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reduction plan; (3) additional resources have been provided to recover

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contaminated areas of the plant' that resulted from the U1, C4 outage and

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plans are to recover these areas ' prior. to the U2, C4 outage; (4) the-

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licensee plans to use more temporary shielding for. the upcoming outage;

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(5) the licensee dons not currently plan to implement the ALARA Standard'

for Nuclear Enginee-ing or provide formal ALARA training other than than

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currently provided in GET or in preparation for special activities, and

(6) the licensee hhs included more senior nembers of .the plant staff on

the ALARA Conrnittee, which is now chaired by the Plant Manager.- The

licensee did not ide~ntify any of'the material provided to, or reviewed by

the inspector dur'.ng the inspection, as proprietary.

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