IR 05000313/1990004

Ack Receipt of 900611 & 0731 Ltrs Re Steps Taken to Correct Violations Noted in Insp Repts 50-313/90-04 & 50-368/90-04

ML20058N145
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/09/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N ENTERGY OPERATIONS, INC.
References
NUDOCS 9008130264
Download: ML20058N145 (3)

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1 Dockets: 50-313/90-04 u 50-368/90-04'

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E  : Entergy Operations',JInc; iE ATTN: NeiliS;-Carns, .Vice President . ,

%. ... Operations,-Arkansas Nuclear One  ;

< . P'.0. Box-551' .

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- Little Rock, Arkansas 72203 4

? Gentlemen: -j

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Thank you for your letters of June 11 and-July 31, 1990,. in response to

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,1 our letter and Notice of Violation dated May 30, 1990. -We have reviewed your  ;

y reply and find it responsive to the concerns raised in our Notice of Violatio We will: review the' implementation of your corrective actions during a future-inspection to' determine that full compliance.has been achieved and will be'

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Sincerely, l

-r9 Gen J)g Samuel J. Collins, Director 4 Division of Reactor Projects ::

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.Entergy Operations, In .

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- ATTN: Donald C. Hintz, Executive  :

.. Vice President-P.O.: Box"31995

' Jackson, Mississippi 39286 >

. Entergy Operations ~,~In . ATTN: Gerald W Muench, Vice President

' Operations Support-P.O.' Box ~31995:

Jackson, Mississippi 39286

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(Wise, Carter, Child'& Caraway-m ' ATTN: ; Robert B.= McGehee, Es P;0. Box 651-

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Jackson ~, Mississippi 39205 Arkansas Nuclear One ATTN: Early Ewing, General- Manage . -

Technical Support and-Assessment

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Russellville ; Arkansas 72801

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Arkansas Nuclear One ATTN:--Jerry Yelverton, Director: >

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$ ATTN: Mr. Tom' W.1 Nickels 3.f ?, -

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' ATTN: Charles'B, Brinkman,' Manager .

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L WashingtontNuclear.0perations 1 12300 Twinbrook Parkway, Suite 330 i

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Honorable: Joe W. Phillip ? County Judge-of-Pope County if

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i U.S. Nuclear ~ Regulatory Commission-l u ' ATTN:-LSeniorlRosident Inspector-

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'l Nuclear 1 Plant Road-Russellville, Arkansas 72801 r M

Li! V,S.-' Nuclear-Regulatory Commission

- ATTN: : Regional Administrator, Region IV

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June 11, 1990

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LU,.S. Nuclear Regulatory Commission l Document Control Desk l l Mail Station P1-137 l

Washington,.D. C. 20555 l l

O' SUBJECT: Arkansas Nuclear One - Units 1 and 2 L Docket Nos. - 50-313/50-368 ,

L-License Nos.-DPR-51 and NPF-6 l Response to Inspection' Report  :)

50-333/90-04; 50-368/90-04 a

Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the  :

deviation and violations identified during the~ inspection of activities associated with the ANO radiological controls programs. In accordance with

- the instructi~ons _provided in the subject inspection report, no written response to violation 313/9004-04; 368/9004-04 is provide Veyy tr ] yours,

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O' m E. C. Ewing l

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General Manager.-  !

Technical Support

'and Assessment ECE/DWB/sms Attachment j cc: Regional Administrator Region IV U.S. Nuclea* Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington', Texas 76011

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/1;2 (* U.'S.[NRC1 " - Attachment

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Notice of Violation I

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% Technical Specification 6.1.8.a for Units 1 and 2 requires'that' written l procedures shall be established, implemented, and maintained covering-

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activities recommended in Appendix A of Regulatory Guide 1.33. Section 9l

7.3 addresses contamination contro j

, J Paragraph 6.4.2 of the _ licensee's Procedure 1622.010: requires the  !

initiation of: decontamination procedures-for contamination of individuals j L

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utilizing the guidelines-provided in Appendix'II, and'that any contaminated- -

hair that cannot be decentaminated must be removed, j, Contrary to the above, on January 31, 1990, the inspectors determined that hair of an individual which was contaminated with 30 nanocuries of cobalt -t 58 on December 20, 1989, could not be decontaminated and the hair was not remove h This is a Severity Level IV violatio (Supplement VI) (313/9004-01; 'j 368/9004-01) i Response to Violation 313/9004-01: 368/9004-01

, Reason for the violation:

To facilitate understanding of this event, the following sequence of events is give ,

'On'Docomber 18,*1989, an ANO-1 Waste Control 0perator (WCO) was contaminated :l" as a result of a relief valve opening. The WC0 was sprayed with water from_the primary system. His hands, face and the back of his head were

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contaminated. He was decontaminated to less than 100 not counts per ,

minute in accordance with Personnel Decontamination procedure 1622.010 and cleared a PCM-1B contamination monitor prior to his release.- A whole' body 'l count the following day indicated a'totaleof 1.4% MPBB (1.2% of which was

'ssCo), wnich indicated external contamination generalized in the surface'of--

the upper bod On December-22,v1989, the WC0 alarmed a PCM-1B upon his exit from the

. controlled access area at the Unit 1 exit location (CA-1). The Health Physics (HP) technician at CA-1 notified th: HP Supervisor on duty and stated that the WC0 had some' detectable ac5 vity in~his hair. The

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supervisor directed the technician to take the WC0 to CA-2 (controlled-access entry location) where he could be frisked in a low background area to determine the extent of contamination. The overall contamination levels

' in the hair located on the back of the WCO's head were approximately 60 ccpm. On a certain section of-his hair, when the hair was clumped together, y '

approximately 100 ccpm was detected. This clump of hair was removed. The remaining hair was refrisked. The highest reading located was approximately 60'cepm, even when the hair was clumped togethe Procedure 1622.010 stated that personnel causing a PCH-1B to alt.rm and exhit,iting greater than or i

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3U equal to 100 cpm above background are subject to' decontamination. As the i a '

w-highest reading was approximately 60 cpm above background, no further '

E decontamination efforts were required by procedure. Appendix II of P 1622.010 contains guidelines which are to be followed for readings greater than or equal to 100 ccp C At about 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br /> onsJanuary*18,m1990,'. the Lead Supervisor, Health  ?

Physics Operations of Louisiana Power and Light Company's Waterford-3 '

Station (W-3) contacted ANO regarding the WC0 who was visiting W-3 for ,

3 training.. When the ANO WC0 exited the W-3 RCA, he alarmed a PCM-1 g F The alarms were for the head, zone 1, and zone.5. He had previously J

' informed the W-3 staff of causing similar PCM-1B alarms at ANO. The W-3 Lead Supervisor called to advise us of the W-3 alarm and to ask" details of the administrative actions taken at ANO. According to the J W-3 Lead Supervisor,;the WC0 had stated that he could not consistently ,

E clear PCM-1Bs but that subsequent frisker checks failed to locate any }

contamination. The W-3 Lead Supervisor was advised to prohibit RCA entry by the WC0 until the matter could be fully understood. The WCO's-W-3 TLD was pulled and he' was restricted to areas outside the RCA for the remainder of his W-3 trainin .

The WCO's whole body counts from Januarf 16;r1990 (an exit count.in  !

preparation for the trip to W-3), back through March 2, 1987, were '

reviewed. The data confirmed he had not incurred significant internal .:

contamination in this time frame based on the levels of contamination,.

the isotopes involved, and biological clearance. The exit (supine)  :

count of January 16, 1990, indicated 8 1 2 nCi of asco which equates to 0.3% MPBB, The profile indicated en.ernal contaminatio Since the investigation limit is 5% MPBB, the indicated activity was almost a factor of 17 below the procedural ection level. In. summary, no uptakes are indicated by the WCO's whole body' count which could cause the repetitive PCM-1B alarms which began in mid-December 198 : Upon leaving W-3, the WC0 returned to ANO on Januaryo20,-1990. A supine 1 (i.e. , normal geometry) whole body count, indicated 611 nCi ssCo'(0.2% 1 MPBB). External contamination.was indicated in the upper body re ion.

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Aprone(i;e., facedown)whole~bodycountindicated19-13nCisgCo .

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(0.7% MPBB) and 3 1 2 nCi s*Mn (0.1% MP88). The shielding of thes skull L and the water and tissue in the cranium accounts for the different L readings between the supine and prone counts. External contamination was' definitely indicated on the back of the head. Subsequent frisking indicated the source was too diffuse and weak to be specifically located and was below the release limit of 100 net counts per minut The WC0 was interviewed by the ANO Unit 1 Assistant Manager Operations and an ANO Health Physics Specialist on" January 20p1990. The WC0 stated that he had experienced PCM-1B alarms at ANO-approximately fifty i percent of the time when he exited the RCA. He sta'ed the repetitive 1 alarms began after the contamination event of December 18, 1989. The alarms were always for the head or upper body. He stated that he had followed procedures each time and had reported to the CA-1 HP technician for frisking or, during backshift when no HP technician was stationed at CA-1, had frisked himself. No contamination was ever located. It is important to note that no individual in the HP organization was aware of the repetitive nature of the alarms. The WC0 retained the

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.Page 3 d

. June 11, 1990 1

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l alarm printouts from the PCM-1Bs each time and compared them to assure himself the reported activity was-not increasing. An increase in activity would have indicated that additional radioactive material had:

been received during an'RCA entr The reported activity was characterized as." barely'over the alarm setpoint." Although the activity reported by the PCM-1Bs was gradually decreasing, the WC0 showed the alarm printout =

to an HP Trainer as a matter of general curiosity. Together, they a briefly reviewed the data and.the trainer confirmed that only small I

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s amounts: of activity were involved and that there was no need for concern since the activity was presumably a-residual from the December-IB,1989, event and was' chemically bound to the hair and skin. They-- -l planned to do a detailed investigation later in January to try to locate and remove the~ activity. Being thus assured of the lack of '

significance of the alarms, the WC0 disposed of the printout I The Unit 1 Assistant-Manager Operations and Health Physics Specialist accompanied the WC0 to the Controlled Access exit location to witness the PCM-1B response first hand. The W-3 and ANO PCM-1Bs are set t elarm at the same cctivity (5000 DPM/100 cm 2 ); therefore, comparing PCM-1B response from the two installations is valid. -The WC0 caused fouralares out of-eight PCM-1B checks. The alarms were.always for-the .i head and/or upper body. These were the same areas which alarmed at W-3. Three of the four alarms were generated on a PCM-1B which printed  !

the alarm activity.. One of the alarms was from activity less than 1%

above the' alarm limit (5 cpm above the alarm limit). The highest of

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the three was from measured activity 9% above the alare limit (59 cpm i greater than'the alarm limit). Dispersed activity of this: low magnitude is consistent with the whole body count data and with the PCM-1B <

repetitive alarms. It would also be unlikely that it could be located u with aifrisker. This level is below the release criterion of 100 net 1 counts per minute-on a friske '

4Although\ procedures-were,followedLin<this event,- s ANO acknowledges a of 'i

,the, weakness repetitiveinPCM-1B<alarmsSby.the.WC the,HPeprograssintthat"the-HP> Eachdepartment wasenot; aware,7a alarm was handled'as single event according to procedure; however, the repetitive nature of ,

the-alarms indicated that action beyond current procedural guidance was appropriate. This-event occurred because there was no method for tracking PCM-1B alarms which would have identified to HP repetitive-alarms which were below the levels requiring decontamination (100 cepm). Corrective steps-taken and the results achieved:

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As part of efforts-to improve access / egress control to the RCA, the decision was made to staff >the CA-1 exit. point.withsan HP,technit.ian 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This wil1~ eliminate the necessity for personneralarming the' PCM-1B during off hours to' perform self-frisking. .When a person alarms the PCM-1B, his/her name will be checked against a list of previously contaminated people and action will be taken accordingly, such as requiring a whole body coun _

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Corrective steps that will be taken to prevent recurrence:

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Implementation of the.CA-1 24-hour staffing'and the list comparison will help prevent recurrence of. events of this typ . Date of full compliane r

' Compliance was achieved with the posting of a 24-hour =HRitechnicianist,

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June 11, 1990 Notice of Violation j Technical Specification 4.3.3.9 for Unit 2 states that each radioactive

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gaseous effluent monitoring instrumentation channel shall be demonstrated operable by performance of the channel check, source check, channel cal.wation, and channel functional test at the frequencies shown in Table 4.3-1 Table 4.3-12 requires the gas activity monitors in the .

Unit 2 spent fuel area ventilation system, auxiliary building area l ventilation system, and auxiliary building extension ventilation system i to be source checked monthl Contrary to the.above, the inspectors determined on January 30, 1990, !

that the General Electric gas activity radiation monitors in the Unit 2 ;

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spent fuel area ventilation system, auxiliary building area ventilation l system, and auxiliary building extension ventilation system had not j been monthly source checked in March, April, May, July, August, October, ;

, November, and December 198 l This is Severity Level IV violatio (Supplement I) (368/9004-02)

Response to violation 368/9004-02 Reason for the violation:

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The violation occurred when procedures changes were made which affected equipment which had Technical Specification surveillance requirements and the changes were not properly incorporated into the Master Test Control List or into the SIMS database, from which the surveillance .

schedule is generated. There were two contributing factors to this ;

pt.sonnel error: (1) the method of processing and reviewing procedure

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y changes, and (2) the fact that there was no single organization at that s time with sole responsibility or ownership for the entire surveillance

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L test progra : Corrective steps taken and the results achieved: .

l Upon identification that the monthly surveillance had not been performed within the required time interval, the monitors were declared inoperabl An entry was made on the plant status board to infom operators about the inoperable monitors and to prevent a corresponding SPING monitor from being taken out of service. Source checks on these monitors were i

completed on February 2,1990, resul'.ing in the monitors being returned '

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to operable statu.. As the source checks were acceptable, the monitors -

were verified to have been functioning properly during the time the surveillance interval had been exceede Therefore, there was no safety significance to this incident.

L To confere with the Technical Specification requirement for monthly I' source checks, the raaf 4 fon monitoring procedure has been revised from the current quarterly source check frequency to a monthly basis.

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. June 11, 1990 i

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j Two changes have been made to enhance the method of reviewing and approving >

procedure changes which affect Technical Specification surveillances. First, '

the Procedure Revision Request Form was revised to require a specific entry .

to denote if a change to the Master Test Control List (M1CL) is neede ;

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The MTCL is the method used to identify the testing requirements associated i with Technical Specifications. If a change to the MTCL is required for a  :

given procedure change, the required effective date for the procedure to be  !

implementen will be assigned when the MTCL is update This will ensure that '

future procedure changes affecting Technical Specification required surveill-ances will be incorporated into the MTCL, Secondly, procedure changes i related to the revision of surveillance procedures will now be reviewed and i approved by the* Surveillance Testing Group, which was recently created to 1 manage the surveillance test program. This group is: ownership of the ,

Technical Specification surveillances, including the responsibility to  !

track Technical Specification suneillar.ces and ensure each surveillance is completed as scheduled, j In addition to these actions, the Unit I anc Unit 2 Technical Specifications  !

, have recently been reviewed to ensure that each surveillance is included  ;

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in the MTCL and addressed by a procedure to ensure performance and adequat ;

documentation. This review verified that the MTCL includes the surveillances  ;

required by Technical Specifications with the exception of a few non-typical surveillances which are effectively tracked by other means. Several 1 surveillance requirements were identified as lacking a procedure to ensure i performanc The majority of the items identified are required strictly '

for post maintenance testing of the ventilation systems and will be addressed Ly a work plan on a case-by-case basis rather than by a permanent ,

plant procc o '

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These measures have helped to ensure that surveillances *.re scheduled, .,

conducted and reviewed as required by Technical Specification : Corrective steps that will be taken to prevent recurrence:

l For those surveillance requirements which were identified as lacking a i procedure to ensure performance, the necessary correctiv(measures v ill be  ;

completed by July 31, 1990. Each of these Technicel Specificatien isouired l surveillances have been identified and docum uted in order to pr(vait an . *

additional missed surveillance prior to the revision and/or developt W. of the appropriate procedure The long term action plan for the Surveillance Testing Group is included in the ANO Business Plan as item C.I. This plan includes a detailed, in-depth review of each Technical Specification survelliance to ensure that the .

existing associated procedure correctly implements the surveillance require-ment and properly documents system operability,

, Date of full compliance:

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Full compliance with the specifics of the violation was achieved with the completion of the source checking of each monitor and the monitors'

subsequent return to service on February 2, 199 The revision and/or development of additional procedures will be completed by July 31, 1990, for the surveillances for which a procedure could not be identified and is determined to be require ,

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Attachment l

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Notice of Violation CFR Part 30.41(c) requires that before transferring byproduct

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l material to a specific licensee,'the licensee transferring the material shall verify that the transferee s li..nse authorizes receipt of this material. Paragraph (d) describes acceptable methods to verify the requirements in paragraph (c).

Contrary to the above, on January 31, 1990, the inspectors identified that the Arkansas Power & Light Company (transferor) transferred byproduct material on September 9, 1989, to a specific licensee i (transferee) without verifying that the transferee was authorized to receive the materia i This is a Severity Level IV violatio (Supplement VI) (313/9004-03; i

368/9004-03) l l i

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Response to violation 313/9004-03 368/9003-03 l

l Reason for the violation The reason for the violation was personnel error. The Radwaste Superintendent stated that prior to the shipment of radioactive materials, the vendor was, in fact, contacted to verify that their '

license was current becrose the license on file at ANO was out of I date. The vendor telef ed a copy of a " letter of renewal", which I was reviewed and determined to be adequate by thi RW Superintenden However, the letter of renewal was subsequently 6 isplaced or los ' Corrective steps taken and the results achieved:

Upon discovery that a current license for the vendor could not be i located, the vendor was immediately contacted and requested to forward  ;

an updated copy of their Radioactive Material License to Alio. The i updated copy of t.he license has been placed in the file The filing system for Radioactive Material Licenses was reviewe Each license in the files was reviewed and verified to be curren Additionally, an electronic copy of each license has been placed in the Radwaste Department's computer database as backup documentatio Revision 18 to Procedure 1603.003, Radioactive Material Shipments,"

was implemented on March 29, 1990, to include a license verification '

sign-off on the shipment paperwork. The individual responsible for

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the shipment must now sign their initials documenting the review of

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the license to verify that it is current and that the vendor is '

authorized to receive the type of radioactive meterials shippe Since the implementation of these corrective measures, only one (1)

radioactive materials shipment has been made. No problems were encountered l regarding the verification of the Radioactive Materials License for the

receiving vendor.

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Page 8 i June 11, 1990  ;

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l Corrective steps that will be taken to prevent recurrence:  ;

Since the occurrence of this incident, CW department personnel now I attach the cover page of the license to the shipping paper documentation t package which is retained as part of the permanent plant records for ,

AN Although this practice is currently not formalized, procedure  :

1603.003, " Radioactive Material Shipments" will be revised to make this '

practice a requirement. This will provide additional documentation to  !

verify that each vendor to whom radioactive material has been shipped was, in fact, authorized to receive the shipment. .The procedure

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i revision effecting these changes will be completed by June 29, 199 , Date of full compliance: I The current Radioactive Material Licents for the vendor was placed in the Radwaste files on February 1 1990. The procedure revision to ,

providealicenseverificationsIgn-offassociatedwiththeshipment paperwork was implemented on March 29, 199 Full compliancy was achieved on that dat Additionally, the procedure enhancement to require the cover page of the license to be attached to the shipment paperwork will be completed by June 29, 199 >

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Attachment-Page 9 .

. June 11, 1990  ;

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Notice of Deviation  !

Chapter 11, paragraph 11.1.3.6.2 of the Unit 1 SAR and Chapter 11, paragraph 11.3.6.11.1 for the Unit 2 SAR state, in part, that gaseous radioactive i

waste is to be compressed to approximately 123 pounds per souare inch gauge '

(PSIG) and stored in the waste gas decay tanks until the radioactivity level of the gases has been reduced sufficiently to allow the gases to be discharged through the discharge header to the environment. During normal operatio :

all radioactive waste gases are to be stored for decay for 30 days or longer to reduce the concentrations of the radioactive gases prior to release to the environmen .

In deviation from the above, on February 1, 1990, the inspectors determined that during 1989 gas docay tanks in Unit 2 were not routinely being pressurized to 123 psig before tht tanks were isolated for storage of radioactive waste gas in both units, and the waste gas tanks were not being isolated and the  ;

radioactive waste gn es stored for decay purposes for 30 days or longe (313/9004-05; 368/9004-05)

Response to deviation 313/9004-05: 368/9004-05 Reason for the deviation: .

To adequately respond to the deviation, a brief discussion is necessary of the Unit 1 SAR and the Unit 2 SAR sections discussing tne waste gas  !

system The deviation cites Chapter 11, paragraph 11.3.6.11.1 of the Unit 2 SA This Releases." paragraph is located This section discesos within section 11.3.6, the estimated annual" Estimated releases from Unit I and Unit 2 with section M.3.6.1 through 11.3.6.10 discussing Unit 2 systems. Section 11.3.6.11 discusses Unit 1 systems, beginning with 11.3.6.11.1, the gaseous radioactive waste system. Thus the section cited was intended to describe Unit 1 only, not Unit 2. The SAR description of the Unit 2 Waste Gas System is located in section .

11,3.2, " System Description."

The deviation cites Chapter 11, paragraph 11.1.3.6.2 of the Unit 1 SAR. This paragraph is located in section 11.1.3.6, " Design Evaluation,"

which was written tu demonstrate the capability of safe operation of the plant far below the release limits specified in 10CFR20, given one percent failed fuel. This section discusses the assumptions made for the evaluation, which include a nominal operating pressure of 123 psig and a 30-day decay period. These are system capabilities, not necessarily descriptions of routine system operations. The Unit 1 Gaseous Radwaste System is described in section 11.1.3.2, which states that the gas is compressed and stored until the activity level drops sufficiently to be released and that the tanks are conservatively sized to provide a 30-day holdup time for deca .

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levels are as low as reasonable achievable. This has not been done in the past because of inadequate procedural guidance in the waste gas l release permit sections of the procedures. The procedural instructions )

contained only brief guidance and placed little emphasis on the 30-day  !

decay tim Although the Unit 1 SAR paragraph 11.1.3.6.2 uses a value'of 123 psig i for pressurization of the waste gas decay tanks, the Unit 1 Gaseous Radwaste System procedure limits waste gas decay tank pressure to 88 psig before isolation of the tanks. This leaves room to dilute the contents of the tank with nitrogen, if necessary. Also, in the event of a nine percent hydrogen burn, the resulting pressure rise would not exceed the tank relief valve setting of 133 psig. Therefore, routine operation o* the Unit I waste gas system will continue to include  ;

limiting the tank pressure to less than 88 psig. The 123 psig value  ;

is not mentioned in the Unit 2 SAR atj is not applicable to Unit . Corrective steps that have been taken and the results achieved:

Procedures 1104.022 and 2104.022 have been revised to incorporate the following: > The tanks will be isolated with Hold Cards *;nstalled on the isolation valves when the tank hold up begins. The number of days the tank has been isolated will be computed from the date the Hold Cards were hun ' The gaseous release permits for both units now contain a note stating that when plant and tank conditions permit, tank contents  !

are to be held for a minimum of 30 days to &110w decay of *

short-lived isotopes, r The shift operations supervisor is directed to provide an  ;

explanation of why the tank must be released if the hold up time is less than 30 day ,

Revision 23 to procedure 1104.022 was approved on May 23,19 Revision 23 to procedure 2104.022 was approved on June 8, 199 . Corrective steps that will be taken to prevent recurrence:

Training sessions are scheduled to address the procedural changes, the ALARA concept associated with waste gas releases, definition of holdup time, effect of holdup time on Xe-133 and Kr-85 concentration / activity, and the expected activity levels for a releas The training for Unit 1 persor.nel will be complete on August 10, 199 The Unit 2 training will be complete on July 20, 199 >

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. Date of full compliancei Compliance with the specifics of the deviation was achieved with the approval of the revised Unit 2 procedure 2104.022 on June 8, 199 (The Unit 1 procedure had been previously approved May 23,1990.)

Training will be completed August 10, 1990, for Unit 1 personnel and July 20, 1990, for Unit .

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AUS -21990 ,

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July 31, 1990

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OCAN879824 U. S. Nuclear Regulatory Commission ,

j Document Control Desk

Mail Station P1-137 Washington, D. C. 20555

$UBJECT: Arkansas Nuclear One - Units 1 and 2 *

Docket Nos. 50-313/50-368 i

License Nos. DPR-51 and NPF-6 Revised Response to Inspection Report i 50-313/90-04; 50-368/90-04 l

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Gentlemen:

Pursuant to the provisions of 10CFR2.201, and conversations between the NRC Region IV staff and members of my staff, attached is the revised response to Notice of Violation 313/9004-01; 368/9004-01 concerning the decontamination of a Unit 1 operator. This submittal supercedes the previous response. Revisions to the original response are indicated by side bars in the left margi Very tr yours, i

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i E. C. Ew L General Manager, Assessment  ;

ECE/JDJ/sgw

[ Attachment

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ec: Regional Administrator Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 1000 -

Arlington, Texas 76011

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Notice of Violation Technical Specification 6.1.8.a for Units 1 and 2 requires that written procedures shall be established, implemented, and maintained covering activities recommended in Appendix A of Regulatory Guide 1.33. Section 7.3 addresses contamination contro Paragraph 6.4.2 of the licensee's Procedure 1622.010 requires the initiation of decontamination procedures for contamin0 tion of 1 individuals utilizing the guidelines provided in Append x II, and that J any contaminated hair that cannot be decontaminated must M remove Contrary to the above, on January 31, 1990, the inspectors determined i that hair of an individual which was contamit.ated with 30 nanocuries )

of cobalt 58 on December 20, 1989, could not be decontaminated and the hair was not remove ;

This is a Severity Level IV violatio (Supplement VI) (313/9004-01;

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368/9004-01) 1 I

l Resnonne to Violation 313/9004-01; 368/9004-01 Reason for the violation!

The violation occurred as stated in that a sufficient amount of hair was not removed to conservatively place the individual below established release limits. This event occurred because management expectations in this area had not been adequately communicated to the HP staf To facilitate understanding of this incident, the following sequence of events is give 't

On December 18, 1989, an ANO-1 Waste Ccntrol Operator (WCO) was contaminated as a result of a relief valve opening. The WC0 was sprayed with wat6r from the primary system. His hands, face and the '

back of his head were contaminated. He was decontaminated to less than 100 not counts per minute in accordance with Personnel Decontamination procedure 1622.010 and cleared a PCM-1B contamination '

monitor prior to his relsase. A whole b*ody count the following day indicated a total of 1.4% MPBB (1.2% of which was "Co), which l.indicatedexternalcontaminationgeneralizedonthesurfaceofthe upper body. No significant internal contamination was indicated.

l On December 22, 1989, the WC0 alarmed a PCM-1B upon his exit from the controlled access area at the Unit 1 exit location (CA-1). The Health Physics (HP) technician at CA-1 notified the HP Supervisor on duty and stated that the WC0 had some detectable activity in his hair. The

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ll supervisor directed the technician to take the WC0 to CA-2 (controlled access entry location) where he could be frisked in a low background i area to determine the extent of contamination. The overall  ;

contamination levels in the hair located on the back of the WCO's head I were approximately 60 ccpm. On a certain section of his hair, when the hair was clumped together, approximately 100 cepm was detecte This clump of hair was removed. The remaining hair was refriske The highest reading located was approximately 60 cepm, even when the hair was clumped together. Procedure 1622.010 stated that personnel causing a PLM-1B to alarm and exhibiting greater than or equal to 100 cpm above background are subject to decontamination. As the highest reading was approximately 60 cpm above background, no further decontamination efforts were required by procedure. Appendix II of ,

1622.010 contains guidelines which are to be followed for readings l greater than or equal to 10') cep j At about 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br /> on Jaavary It , 1990, the Lead Supervisor Health Physics Operations of Loubiana rower and Light Company's Waterford-3 Station (W-3) contacted ANO regarding the WC0 who was visiting W-3 for ,

training. When the ANO WC0 exited the W-3 RCA, he alarmed a PCM-1 l The alarms were for the head, zone 1, and zone 5. He had previously l informed the W-3 staff of causing similar PCM-1B alarms at ANO. The i W-3 Lead Supervisor called to advise us of the W-3 alarm and to ask  ;

details of the administrative actions taken at ANO. According to the W-3 Lead Supervisor, the WC0 had stated that he could not consistently clear PCM-1Bs but that subsequent frisker checks failed to locate any '

contamination. The W-3 Lead Supervisor was advised to prohibit RCA entry by the WC0 until the matter could be-fully understood. The ,

WCO's W-3 TLD was pulled and he was restricted to areas outside the '

RCA for the remainder of his W-3 trainin ;

The WCO's whole body counts from January 20, 1990 (including an exit  ;

count on January id, 1990, in preparation for the trip to W-3.and a  :

count on January 20, 1990, upon his return from W-3), dating back -

through March 2, 1987, were reviewed. The data confirmed he had not incurred significant internal contamination in this time frame based t on the-levels of contamination, the isotopes involved, and biological '

clearanc l The WC0 was interviewed by the ANO Unit 1 Assistant Maaager Operations and an ANO Health Physics Specialist on January 20, 1990. The WC0 stated that he had experienced PCM-1B alarms at ANO approximately fifty percent of the time when he' exited the RCA. He stated the repetitive alarms began after the contamination event of December 18, 1989. The alarms were always D r the head or upper body. He stated that he had followed procedures each time and had reported to the CA-1

HP technician for frisking or, during backshift when no HP technician was stationed at CA-1, had frisked himself. No contamination was ever l located. It is important to note that no coecific individual in the ,

HP organization was aware of the repetitive nature of the alarm . - - - -

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The WC0 retained the alarm printouts from the PCM-1Bs each time and )

compared them to assure himself the reported activity was not increasing. An increase in activity would have indicated that additional radioactive material had been received during an-RCA entr The reported' activity was characterized as " barely over the alarm setpoint." Although the activity reported by the PCM-1Bs was gradually decreasing, the WC0 showed the alarm printouts to an HP 1rainer as a matter of general curiosity. Together, they briefly 3 reviewed the data and the trainer confirmed that only small_ amounts of i activity were involved and that there was no need for concern since i the activity was presumably a residual from the December 18. 1989, i event and was chemically bound to the hair and skin. They planned to do a detailed investigation later in January to try to locate and remove the activity.. Being thus assured of the lack of significance of the alarms, the WC0 disposed of the printout l The Unit 1 Assistant Manager Operations and Health Physics Specialist accompanied the WC0 to the Controlled Access exit location to witness  ;

the PCM-1B response first hand. The W-3 and ANO PCM-1Bs are set to l alarm at the same activity (5000 DPM/100 cm'); therefore, comparing l PCM-1B response from the two installations is valid. The WC0 caused <

four alarms out of eight PCM-1B checks. The alarms were always for j

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the head and/or upper body. These were the same areas which alarmed at W-3. Three of the four alarms were generated on a PCM-1B which printed the alarm activity. One of the alarms was from activity less than 1% above the alarm limit (5 cpm above the alare limit). The i

i l highest of the three was from measured limit (59cpmgreaterthanthealarmlimit). activity 9%

Dispersed above the alarm external

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activity of this low magnitude is consistent with the whole body count '

L l data and with the PCM-1B repetitive alarm . Corrective stens taken and the results achieved: ,

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H An event of this nature is not consistent with ANO current philosophy i

[ and policy of conservative operations. Proper conservatism in

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decontamination practices and procedures that will prevent recurrence ,

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of such an incident h n oeen communicated via memorandum to the HP staff.

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p The following additional actions have been taken:

L . The CA-1 exit point has been staffed with an HP technician 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l per day. This will eliminate the necessity for personnel alarming '

L the PCM-1B during off hours to perform self-friskin * A tracking program has been established to identify repetitive PCM-1B alarms associated with previously contaminated individual This process will continue to be evaluated to ensure effective tracking of repetitive alarm ._ _ _ ___ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ , _ _ -_ ~ _ _ _ _

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e Communica.ing the responsibility of the HP department to the HP  :

i staff has been initiated regarding indications of dispt:rsed i activity of a low magnitude as it relates to skin contamination and -

the course of action to be followed. Emphasis 's beirg placed on the shielding / masking effects that can occur if an ind.ividual's skin or hair is not completely dried before surveying (a suspected contributing factor to the event cited.in this violation), dead zones associated with monitoring equipment, proper survey techniques, procedural compliance, and notification and involvement ,

of the HP supervisor ' Corrective stens that will be taken to nrevent recurrence:

Specific communication meetings will be conducted',ith the HP 4taf The purpose of these meetings will be to convey management's .

expectations regarding AN0's current philosophy and policy of conservative operations regarding decontamination practices and i procedures. Additionally, a memorandum summarizing management's expectations for each ANO employee will be distributed to ANO personnel. These actions will be completed by August 31, 199 ' Date of full como11ance Compliance was achieved with the issuance of the memorandum communicating the policy to the HP staff, the postinc of a 24-hour HP technician at CA-1, and implementation of the track'.ng program. . Full compliance will be completed by August 31, 1990, p'ending completion of the specific communication meetings with the HP s',aff, i

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