ML20245L319

Insp Repts 50-327/89-11 & 50-328/89-11 on 890626-30. Violations Noted.Major Areas Inspected:Radiation Protection Program,Follow Up on Previous Inspector Identified Items & IE Info Notices

ML20245L319
Person / Time
Site:	Sequoyah
Issue date:	08/01/1989
From:	Collins T, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245L305	List: ML20245L300 ML20245L313 ML20245L319
References
50-327-89-11, 50-328-89-11, IEIN-89-027, IEIN-89-27, NUDOCS 8908220078
Download: ML20245L319 (7)

See also: IR 05000327/1989011

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LReport Nos.: 50-327/89-11 and:50-328/89-11

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1w . Docket Nos.:'50-327 and'50-328 -License Nos.: DPR-77and[DPR-79 '

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4 ' Inspection'Condu ed) J n :2 -30, 1989 _1-

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.J. #. Potter, Chief Irafe Signed

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Facilities-Radiation Protection Section 't

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SUMMARY

Scope:

This routine, unannounced inspection was conducted in the area of the radiation

protection program follow-up on previous inspector identified items and

a: 'IE'Information Notices.

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1Results:=

Based .on" interviews with licensee management, supervisor and personnel from

station departments, and records review, the inspector found that the radiation

protection program was generally adequate.

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Hewever. one . violation was

identified: 1)cfailure to ' adequately train personnel in use of radiation

protection equipment and-failure to evacuate an area when a radiation monitor

' alarmed as required by Radiological Control Instructions.

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REPORT DETAILS

1. Persons Contacted

, Licensee Employees

-M. Edwards, ALARA Engineer.

• T. Flippo, Quality Assurance Manager

E. Hickman, Radiological Protection Manager

• S. Holderfer, Health Physicist

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• C. Mason, Plant Manager

M. Palmer, Radiological Health Manager

• R. Pierce, Mechanical Maintenance Group Manager

• S. Spencer Nuclear Engineer

J. Stiegleman, Radiological Controls Manager

M. Sullivan, Radiological Control Superintendent

Other licensee employees contacted during this inspection included

engineers, operators, mechanics, technicians, and administrative

personnel.

Nuclear Regulatory Commission

P. Harmon, Senior Resident Inspector

• K. Jenison, Senior Resident Inspector

D. Loveless, Resident Inspector

• Attended exit. interview

2. Occupational Exposure, Shipping, and Transportation (83750)

a. Organization

The licensee was required by Technical Specification (TS) 6.2 to

implement the plant organization specified in Table 6.2.2-1. The

responsibilities, authorities, and other management controls were

further outlined in Chapters 12 and 13 of the Final Safety Analysis

Report (FSAR). TS 6.5.1 specifies the members of the Plant

Operations Review Committee (PORC) and outlined its functions and

authorities. Regulatory Guide 8.8 specifies certain functions and

responsibilities to be assigned to the Radiation Protection Manager

(Radiological Control Superintendent) and radiation protection

responsibilities to be assigned to line management.

The inspector reviewed recent changes and proposed changes to the

plant organization to determine their effect on plant radiological

controls, by examining the resulting changes to administrative

procedures and position descriptions and discussed the changes with

the Plant Manager and the Radiological Control Superintendent.

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The inspector discussed with a Radiological Control Manager, a

Radiological Controls Foreman, a Maintenance Supervisor, and a

representative from plant engineering, the type, methods of, and

degree of interaction between plant groups. The inspector discussed

with the Radiological Controls Superintendent and selected

radiological controls personnel, how frequently they toured the

plant, radiation control areas (RCAs) and reviewed documentation of

'these tours. The inspector also accompanied a Radiological Controls

Manager on a scheduled tour of the RCA on June 27, 1989. During this

tour, the inspector observed work in progress and posting of controls

for RCAs.

No violations or deviations were identified.

b. Staffing

TS 6.2.2 specifies minimum plant staff and FSAR Chapters 12 and 13

also outline further details on staffing. The inspector discussed

authorized staffing levels versus actual on-board staffing separately

with the Plant Manager and the Radiological Controls Superintendent.

The inspector concluded that the licensee's current staffing and

experience levels of the radiological controls section were adequate

to support routine plant operations.

No violations or deviations were identified.

c. Control of Radioactive Materials and Contamination, Surveys, and

Monitoring

The licensee is required by 10 CFR 20.201(b), 20.401, and 20.403 to

perform surveys to show compliance with regulatory limits and to

maintain records of such surveys. Chapter 12 of the FSAR outlines

survey methods and instrumentation. TS 6.8.1 requires the licensee to

follow written procedures. Radiological control procedures further

outline survey methods and frequencies.

During plant tours, the inspector observed radiation level and

contamination survey results outside selected cubicles. The

inspector performed independent radiation level surveys of selected

areas hnd observed satisfactory comparison with licensee survey

results. The inspector reviewed selected survey records for the

month of June 1989, and discussed with licensee representatives

methods used to disseminate survey results. The inspector also noted

that only approximately eight percent of the RCA was controlled as

contaminated.

No violations or deviations were identified.

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d. High Radiation Areas

10 CFR 19.12 requires in part that all individuals working in or

frequenting any portion of a restricted area shall be kept informed

of the storage, transfer, or use of radioactive materials or of

L radiation in such portion of the restricted area; shall be instructed

in the health protection problem associated with exposure to such

radioactive materials or radiation, in precautions or procedures to

minimize exposure, and in the purposes and functions of protective

devices employed.

TS 6.8.1 requires that written procedures shall be established,

implemented and maintained in accordance with the applicable

procedures recommended in Appendix A of Regulatory Guide 1.33,

Revision 2, February 1978, Section 7.e. . Radiation Protection

Procedure.

Radiological Control- Instruction RCI-1 Radiological Control Program,

Revision 36, dated August 13, 1988, Section 4.15 requires that all

individuals shall ~immediately evacuate the area and notify RADCON

upon observing a Rad Monitor alarming.

On February 2,1989, two auxiliary unit operators (AU0s) were working

in a pipe chase on Unit 2, elevation 690, posted as a radiation area.

While performing valve operations for recirculation of the refueling

water storage tank (RWST) to accommodate a chemistry sample a

portable area radiation monitoring (ARM), Ludlum Model-300, alarmed.

Preliminary investigation and interviews with the two AU0s determined

that the ARM was reset and the two AU0s continued to work in the

area. At an undetermined time later the ARM alarmed again. The two

AU0s stopped work to read their self-reading pocket dosimeter (SRPDs)

(0-200 mrem) and noted they were offscale. Recirculation operations

were secured and the two AU0s exited the area and notified health

physics (HP). One AU0's thermoluminescent dosimeter (TLD) read

430 mrem and the other's TLD read 479 mrem. These readings reflected

doses for the quarter, however a majority of the AU0s' doses were

received as a result of this event. Radiation levels in the Unit 2,

690 foot elevation Pipe Chase were measured to be 2,500 mrem / hour on ,

contact with the RWST recirculating piping and 500 mrem / hour in the

general area.

Licensee management representatives were informed that this event was

first discussed in NRC Inspection Report No. 50-327, 328/89-05 issued

on March 16, 1989. In a letter dated July 14, 1989, the NRC notified

the licensee that a revised Notice of Violation relating to this

event would be issued in NRC Inspection Report No. 50-327, 328/89-11.

The inspector informed licensee management representatives that

failure to adequately train personnel in the use of portable ARMS

(Ludlum Model-300) and failure of the two AV0s to evacuate the Unit 2

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Pipe Chase when the ARM alarmed was an apparent violation of

10 CFR 19.12 and'TS 6.8.1 (50-327, 328/89-11).

e. As Low As Reasonably Achievable (ALARA) Program

10 CFR 20.1(c) states that persons engaged in activities under

licenses issued by the NRC should make every reasonable effort to

maintain radiation exposure ALARA. The recommended elements of an

ALARA program are contained in Regulatory Guide 8.8, Information

Relevant to Ensuring that Occupational Exposure at Nuclear Power

Stations will be ALARA and Regulatory Guide 8.10, Operating

Philosophy for Maintaining Occupational Radiation Exposures ALARA.

The inspector discussed the ALARA goals and objectives for 1989 with

licensee representatives and reviewed the person-rem estimates and

results. The licensee's goal for 1989 was set at 625; however, the

licensee revised its goal to 725 person-rem due to the person-rem

expended during a refueling / maintenance outage in the spring of 1989.

The licensee expended 675 person-rem through June 1989. If the l

licensee maintains its desired goal of 725 person-rem for 1989, that

would be slightly higher than the national average for 1988 of 692

person-rem for a two unit pressurized water reactor (PWR).

No violations or deviations were identified.

3. Inspector Follow-op Items (92701)

a. (Closed) Inspector Follow-up Item (IFI) 50-327, 328/88-04-01. This

item concerned the processing, pre-job reviews and actual termination

dates on radiation work permits (RWPs). The inspector reviewed and

verified that the licensee has revised RCI-14, RWP Program and

incorporated the above mentioned issues. The RCI-14 RWP Program was i

approved and issued on April 4, 1988.

b. (Closed) IFI 50-327, 328/88-31-03. This item addressed the concern

for formal implementation of a " Hot Particle Program." The inspector

reviewed and verified that this licensee has formally addressed the j

" Hot Particle Program" in appropriate Radiation Protection j

Procedures.

c. (Closed) IFI 50-327, 328/88-31-04. This item concerned a lack of

coordination of insulation workers receiving radiation exposures

while in support of maintenance activities in containment. The

inspector discussed this issue with licensee maintenance

representatives and determined that a temporary position for an

insulator coordinator has been approved. This position's

responsibility is to help reduce the exposure dose rates accumulated

by craft personnel performing insulation work during daily work y

schedules and outage periods. I

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d.. (C1nsed) IFI 50-327, 328/89-05-01. This item addressed'the concern

for heet. stress to workers while wearing supplied air hoods inside

the steam generators. The inspector discussed this issue with

licensee representatives and determined that the licensee routed the

breathing air throt. ;h n ice. filled 55 gallon drum to lower the air

i temperature and wors .. stress for workers breathing the supplied air

L was reduced. No .1.ther complaints were received from steam

generator personnel.

e. (Closed) IFI 50-327, 328/89-05-02. This item concerned the

licensee's air sampling techniques while performing dewatering

operations of-spent resin. The inspector discussed this issue with

licensee representatives and determined by review that the licensee

has revised their Airborne Radioactivity Survey Procedure, HPSIL-5,

Revision 32, dated June 29, 1989, in regard to evaluating and taking

appropriate air samples while performing related activities prior to

and during work progressing.

f. (Closed) IFI 50-327, 328/89-05-03. This item concerned that the

licensee did not track or trend Personnel Contamination Reports

(PCRs) to determine the categories for causes of the events. The

inspector discussed this issue with licensee representatives and

determined by review that the licensee has developed a computerized

PCR trending report to identify each event cause.

However, the inspector noted that the PCR trending report was not

reviewed on a specified frequency to evaluate root causes and

subsequently reduce the PCR events. The licensee acknowledged the

inspector's concern and stated they would incorporate this review

into their Work Routines Program and perform this review on a monthly

frequency.

g. (Closed) IFI 50-327, 328/89-05-05. This item concerned the licensee

performance of analytical evaluations of the high beta radiation

levels in the nozzle dams of the Unit 2 steam generator. The j

inspector reviewed several analytical evaluations performed by the

licensee - to determine the radionuclides composition in the Unit 2

steam generator nozzle dams. The inspector concluded that these

analytical evaluations did not reveal any higher than normal isotopic .

concentrations normally found inside the reactor coolant.

h. (Closed) IFI 50-327, 328/89-05-06. This item concerned the higher

than anticipated airborne radiciodine concentrations in the Unit 2

containment. The inspector discussed this issue with licensee

management representatives and was informed that the licensee '

completed their evaluation and investigation for the reasons why the

airborne radiciodine concentrations were hight.r than anticipated.

The investigation revealed that the purge system eductor inside

containment was installed improperly, so that, rather than removing

the radiciodine from the containment atmosrhere, radiciodine was

being vented into containment through tl e perge system.

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." i. (Closed) . IFI . 50-327, 328/89-05-07. This item concerned the use of

magnetic signs on laundry containers revealing that the laundry was

" clean laundry" rather than contaminated laundry. The inspector

toured the RCA and verified that clean laundry containers were

appropriately marked and labeled as clean. )

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IE Information Notices (IEN) (92717)

The inspector determined that the licensee had received IEN 89-27

" Limitations on the use of Waste Forms and High Integrity Containers for j

the Disposal of_ Low Level Radioactive Waste."

5. Exit Interview

The inspection scope and results were summarized on June 30, 1989, with

those persons indicated in Paragraph 1. The inspector described the areas

. inspected and discussed in detail the inspection results listed below.

The licensee acknowledged the inspection findings and took no exceptions..

The licensee did not identify as proprietary any of the material provided

to or. reviewed by the inspector during the irtpection. The licensee was.

informed that the. items discussed in Paragraph 3 were considered closed.

Item Number Description and Reference

50-327, 328/89-11-01 VIO - Failure to adequately train

personnel in radiation safety equipment

and failure of personnel to evacuate an

area when a radiation monitor alarmed

as required by Radiological Control

Instructions

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