IR 05000313/1998013
| ML20216F063 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/14/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20216F047 | List: |
| References | |
| 50-313-98-13, 50-368-98-13, NUDOCS 9804160407 | |
| Download: ML20216F063 (19) | |
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ENCLOSURE
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l U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-313
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j 50-368 License Nos.:
DPR-51 NPF-6 Repo't No.:
50-313/98-13
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l 50-368/98-13 l
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Units 1 and 2 Location:
Junction of Hwy. 64W and Hwy. 333 South Russelville, Arkansas Dates:
March 30 through April 3,1998 Inspector (s):
Michael P. Shannon, Senior Radiation Specialist Michael C. Hay, Radiation Specialist Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:
Supplemental Information
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9004160407 980414 PDR ADOCK 05000313
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2-EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report 50-313/9813; 50-368/98-13 This announced routine inspection reviewed the radiation protection program focussing on Unit 1 refueling outage activities. Areas reviewed included: exposure controls, controls of j
radioactive material and contamination, surveying and monitoring, the program to maintain occupational exposure as low as is reasonably achievable (ALARA), contractor training and qualifications, and quality assurance in radiation protection activities.
Plant Sucoorf Overall, a good extemal exposure control program was in place. High and locked high
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radiation areas were properly controlled and posted. in general, workers were knowledgeable of work area radiological conditions. (Section R1.1)
A violation, with four examples, was identified involving the failure to determine
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radiological conditions in work areas before issuing radiation work permits. This violation was similar to a violation identified in NRC Inspection Report 97-15. Corrective actions were not effective to correct the previous violation. (Section R1.1)
An effective internal exposure control program was implemented. Continuous air
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monitors and lapel samplers were used to properly monitor worker radiological airbome conditions. High efficiency particulate air filter ventilation units were appropriately used to control airborne concentrations. The whole-body counter calibration program was appropriately implemented. (Section R1.2)
A violation, with two examples, was identified involving the failure to maintain procedures
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consistent with 10 CFR Part 20 requirements. One example was a radiological survey procedure in which the word "should" was used in lieu of "shall' as required by 10 CFR 20.1501(a). The second example involved a bioassay procedure which entailed a method for calculating committed effective dose equivalent from the inhalation of radioactive material using uptake values in lieu of intake values as required by 10 CFR 20.1204(h)(1) when using the conversion factor that one ALI (annual limit on intake) is i
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equivalent to 5 rems. (Section R1.2 and R3.1)
ALARA personnel were appropriately involved during the planning stages of outage
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work. (Section R1.3)
In general, radiological surveys were documented in a clear, consistent mannar, and
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were easy to read and understand. Effectise controls were in place to prevent the l
spread of radioactive contamination. (Section R1.4)
A violation was identified for the failure to perform a radiological survey prior to workers
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installing rigging on the polar crane resulting in four personnel contamination events.
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-3-The failure to survey was a result of mis-communications between the craft workers and health physics staff involving the location of the actual work area. (Section R1.4)
An effective ALARA program was implemented. Outage exposure goals were
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challenging. The person-rem exposure for both units during 1997 was 117. This was the lowest exposure in the operational history of the Arkansas Nuclear One.
(Section R 1.5)
Contractor senior radiation protection technician training and qualification programs were
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effectively maintained. Station radiation protection management was appropriately involved in the development and monitoring of these programs. (Section R5.1)
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Quality assurance radiation protection activities were good. One operational radiation I
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protection-based quality assurance surveillance was performed, which provided management a good overview of the area reviewed. Radiological condition report recommendations to prevent a recurrence appeared to be appropriate. (Section R7.1)
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-5-Report Details
Summary of Plant Status Unit 1 was in the first week of a refueling outage. Unit 2 operated at full power.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Extemal Exoosure Controls a.
Insoection Scooe (83729)
Radiaticn workers and radiation protection personnel involved in the external exposure control program were interviewed. Serveral tours of the radiological controlled area, including the Unit i reactor building, were performed. The following items were reviewed:
Control of high and locked high radiation areas
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Radiation work permits
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Job coverage by radiation protection personnel
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Housekeeping within the radiological controlled area
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Personnel dosimetry
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b.
Observations and Findinas The inspectors noted during tours of the radiological controlled area that high radiation areas were properly posted and controlled. All Technical Specification required doors were either locked or properly controlled.
The inspectors attended several radiation protection supervisor and technician turnover meetings. The inspectors determined that the meetings were informative, comprehensive, and provided appropriate detail which resulted in a smooth transition for shift relief.
The radiation work permit numbering system, which used the same number for similar work with the exception of the year designator, made it easy to review job history information. Radiation work permits were broken into tasks forjobs requiring more than one evolution. The inspectors determined that the radiation work permit tasks were divided into logical steps which provided good guidance to outage workers.
During the review of the radiation work permits, the inspectors identified the following examples of active radiation work permits which failed to determine expected radiological conditions for work prior to issuing the radiation work permit:
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-6-Examole 1: Radiation Work Permit 1-1998-1056, Revision 0, "RCP-D Seal Replacement," listed general radiation and contamination levels for the Unit 1 reactor building north cavity platform where the "D" reactor cooiant pump is located. However, the inspectors noted that no radiation or contamination levels were listed for the "D" reactor coolant pump seal package. Industry experience has shown that the removal of the seal package, rather than the general radiological conditions on the platform, would be the most significant radiological hazard encountered during this task. However, expected radiological conditions and specific controls were not evaluated prior to issuing the radiation work permit.
Examole 2: Task 2 of Radiation Work Permit 1-1998-1042, Revision 1, "R/R (remove and replace) Steam Generator manways, Full and Partial entries, and Steam Generator support Activities," covered activities associated with the removal and replacement of the manway and diaphragm covers. The inspectors noted that Task 2 listed the general radiation and contamination levels for the steam generator upper and lower platforms, however, no radiation or contamination levels were listed for the manways or diaphragm covers, which were the most significant radiological hazards associated with Task 2.
During the review of this task, the inspectors noted that the lower platform contamination levels were listed as greater than 100,000 disintegrations per minute per 100 centimeters
squared (dpm/100cm ), but did not establish an upper limit that was evaluated.
Examole 3: Task 3 of Radiation Work Permit 1-1998-1042, Revision 1, involved conducting partial entries (upper body entries) into the steam generator bowls. The following radiation work permit information was identified by the inspectors prior to the task being performed: (1) Radiation and contarnination levels for upper and lower steam generator bowls were listed for both A and B steam generators. However, the B upper bowl steam generator had listed general and maximum radiation levels of 20 and 800 millirems per hour, respectively. A review of historical thermoluminesent dosimetry
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survey data for B upper bowl revealed that the general and maximum radiation levels for partial er,tries were approximately 3000 millirems and 7000 millirems, respectively. (2)
Discrepancies for the contamination levels for both steam generator upper and lower bowls were noted. Contamination levels for the A steam generator lower bowl were not listed, B steam generator upper and lower bowls, and A steam generator upper bowl had listed contamination levels of 20K to 80K, which did not accurately reflect historical survey data that indicated contamination levels ranged from approximately 340,000
2 dpm/100cm to as high as 48 mrad /100cm.
Examole 4: Task 4 of Radiation Work Permit 1-1998-1042, Revision 1, involved full body entries into the steam generators. The following radiation work permit information was identified by the inspectors prior to the task being performed: (1)The same radiation levels which were listed for Task 3 (upper body entries) were also used for Task 4 (full entries). The historical steam generator survey data revealed that the highest radiation levels were approximately 15 rem per hour and general radiation levels ranged from approximately 6-8 rem per hour. (2) Contamination levels used for this task were the same as those used in Task 3 and did not accurately reflect the historical data.
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7-Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulctory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e.1, includes procedures for access control to radiation areas, including the radiation work permit system. Section 6.2.1 of Procedure OP1012.019, " Radiation Work Permits," Revision 6, states, in part, "When the need for an RWP is identified, determine the following: (A) Radiological conditions for the proposed work area using one or more of the following methods: (1) live time information, (2) routine survey data, (3) historical information, or (4) anticipated conditions."
The above examples of radiation work permits which failed to determine, prior to issuance, expected radiological conditions for the proposed work is considered a violation of Technical Specification 6.8.1.a. (50-313/9813-01). The inspectors determined that this violation was similar to a violation identified in NRC Inspection Report 97-15; however, corrective actions were not effective to correct the previous violation.
The inspectors noted that recording inaccurate radiological survey information or omitting important information on radiation work permits, could cause an incorrect evaluation of the radiological controls needed to safely accomplish a task, or a worker to mis-understanding of the actual radiological conditions in the work area.
Overall, field interviews with outage workers revealed that they were knowledgeable of the general radiological conditions in their work area. The workers were questioned regarding general dose rates, general contamination levels, and airborne conditions. Job coverage by radiation protection technicians was appropriate for tasks observed.
All radiation workers observed wore their dosimetry property. When questioned, workers
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knew to leave their work area and contact radiation protection personnel if their electronic dosimeter alarmed.
The inspectors determined that housekeeping within the radiological controlled area was fair, considering the plant was in the first week of the refueling outage.
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Conclusion In general, a good external exposure control progran, was in place. However, a violation was identified for the failure to properly determine the texpected radiological conditions in a work area before issuing radiation work permits. This violation was similar to a violation identified in NRC Inspection Report 97-15. Corr 6ctive actions were not effective to correct the violation. High and locked high radiation areas were properly controlled and posted. In general, workers were knowledgeable of their work area radiological condition ;*
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8-R1.2 Internal Exoosure Controls a.
Insoection Scone (83729)
I Selected radiation protection personnel involved with the internal exposure control
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program were interviewed. The following items were reviewed:
Air sampling program, including the use of continuous air monitors and filtration
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units Respiratory protection program
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Whole-body counting program, including the calibration of the counter
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The intemal dose assessment program
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b.
Observations and Findinas The inspectors noted proper use of continuous air monitors throughout the radiological controlled area. High efficiency particulate air filter ventilation units were appropriately used to limit airborne exposures to workers.
l The inspectors noted that job coverage air sampling was appropriate for tasks observed, and the licensee effectively used lapel air samplers to monitor a worker's breathing zone.
Whole-body counters were verified to be calibrated using standards traceable to the National Institute of Standards and Technology. The inspectors noted that an acceptable phantom was used along with radiation sources that covered energy ranges between approximately 88 - 1836 kev. The whole-body counting systems were calibrated annually and " prior to use" quality control (source) checks were properly performed.
Evaluations for determining internal doses performed by the licensee were reviewed.
During this review the inspectors noted that Procedure 1601.209, 'Whole body counting / bioassay," Revision 6, contained a methodology for estimating committed effective dose equivalent in a manner which was not consistent with 10 CFR Part 20.1204(h)(1) requirements.10 CFR Part 20.1204(h)(1) states, in part, "In order to calculate the committed effective dose equivalent (CEDE), the licensee may assume that the inhalation of one annuallimit of intake results in a committed effective dose equivalent of 5 rems." Section 6.7.3.B.2 of the above procedure, states, in part,"using l
the appropriate stochastic annual limit for intake (SALI) value from attachment 5 (attachment 5 lists stochastic annuallimits for intake from 10 CFR Part 20, Appendix B.
Table 1), calculate the committed effective dose equivalent for each radionuclide listed on the whole-body count results (WBC)," using the following formula:
I gggg, WBC muMuCD y5g,,
SALI The inspectors questioned the licensee on how whole-bcdy count results, (which is an indication of the amount of radioactive material deposited in the body, also referred to as
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the uptake), were converted to an intake value. The licensee responded that they were determining the uptake value and not an intake value. The inspectors determined that in order to use the above procedural method to calculate the committed effective dose equivalent, a conversion factor needed to be used which takes into account the fraction of material inhaled that is retained in the body and the effective half life of the materialin the body in order to correctly follow the 10 CFR Part 20.1204(h)(1) requirement.
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The inspectors reviewed severalinternal dose calculations performed by the licensee.
One calculation, involving a whole body count which was performed approximately one day following the uptake, was found to be in error by approximately 58%. The licensee's dose calculation using the inappropriate method was 21 millirems, the inspectors calculated the internal dose independently using an acceptable method with a result of 36 millirems. During discussions with the inspectors, the licensee agreed that their procedural method of calculating the committed effective dose equivalent was non-conservatively in error and needed to be changed incorporating an acceptable method.
These changes were not completed for review during the inspection.
Upon further review of Procedure 1601.209, "Whole body counting / bioassay," Revision 6, the inspectors noted that Section 6.7.6 states, in part, "The Dosimetry Supervisor reviews Form 1601.2090 (internal dose calculation sheet) and initiates additional actions, as necessary." The inspectors asked if any additional actions had ever been conducted for any uptakes. The licensee responded that one ingestion of radioactive material occurred September 1996 in which a computer code was used for calculating the dose, i
and all other internal dose calculations were performed by using the above procedural method. The inspectors determined that the inappropriate method used by the licensee for estimating internal doses as a result of inhalation of radioactive materials to be a j
programmatic problem that could potentially result in a seriw underestimate of l
personnel dose.
Technical Specification 6.10 (Unit 1)/6.11 (Unit 2) states that procedures shall be prepared consistent with the requirements of 10 CFR Part 20.10 CFR 20.1204(h)(1)
states, in part, that in order to calculate the committed effective dose equivalent the licensee may assume that the inhalation of one All results in a committed effective dose equivalent of 5 rems.
The failure to prepare Procedure 1601.209, 'Whole-body counting / bioassay," Revision 6, consistent with the requirements of 10 CFR Part 20 is considered the first example of a
j violation of Technical Specification 6.10/6.11 (50-313;-368/9813-02).
During discussions with licensee staff, the inspectors were informed that Arkansas Nuclear One was recording internal exposures at a lower threshold than required by regulations. The inspectors acknowledged that Arkansas Nuclear One was recording internal exposures at a lower threshold than was required by regulations; however, since this information is being used for a dose of record, the inspectors commented that internal exposures needed to be estimated in an acceptable manner. The licensee acknowledged the inspectors' commen *
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Conclusions Continuous air monitors and high efficiency particulate air filter ventilation units were appropriately used to monitor and limit airborne exposures to workers. The licensee effectively used lapel air samplers to monitor workers' radiological airborne conditions.
The whole-body counting program was effectively implemented. A first example of a violation of Technical Specifications 6.10/6.11 was identified that involved a bioassay procedure which entailed a method for calculating committed effective dose equivalent from the inhalation of radioactive material using uptake values in lieu of intake values as required by 10 CFR 20.1204(h)(1) when using the conversion factor that one ALI is equivalent to 5 rems.
R1.3 Plannina and Preoaration a.
Insoecthn Scone (83729)
Radiation protection and chemistry department personnelinvolved in radiation protection planning and preparation were interviewed. The following items were reviewed.
ALARA job planning
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ALARA packages
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Incorporation of lessons teamed from similar work
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Supplies of radiation protection instrumentation, protective clothing, and
consumable items I
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Observations and Findinas The inspectors noted that radiological work package tasks were planned well and ALARA personnel were appropriately involved during the planning stages. Lessons learned from past similar work were incorporated into the radiological work packages.
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Post-job briefings were held which captured lessons learned. Ideas were captured from l
craft level personnel, in addition to engineers and ALARA planners. At the completion of j
l the task, job history comments were provided to the Al. ARA job planners for evaluation l
and incorporation of lessons learned.
Appropriate inventories of clothing, monitoring instrumentation, protective clothing, and
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consumable items were provided.
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Conclus. tons ALARA personnel were appropriately involved during the planning stages of outage work.
R1.4 Control of Radioactive Materials and Contamination: Surveyina and Monitorina a.
Insoection Scoce (83729)
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-11-Areas reviewed included:
Contamination monitor use and response to alarms
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Control of radioactive material
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Source inventory and control programs
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Portable instrumentation calibration and performance checking programs
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- Adequacy of the surveys necessary to assess personnel exposure
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b.
Observations and Findinas Controls
Observations at the radiological controlled area access revealed that personnel exiting the radiological controlled area used the personnel contamination monitors properly, Radiation protection (RP) personnel assigned to monitor the control point responded
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properly to personnel contamination alarms, provided proper guidance to workers who alarmed the monitors, and were knowledgeable of appropriate actions to take regarding the handling of personnel contamination events and release of material from the -
radiological controlled area. The review of personnel contamination logs revealed that all information was recorded in accordance with station procedures.
The licensee provided good controls to prevent the spread of radioactive contamination.
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Contaminated areas were properly posted and marked with tape and rope. Trash and laundry barrels were properly maintained. Step-off pads were placed at the entrances / exits to these areas. High efficiency particulate air vacuums and containers of radioactive material observed were properly labeled. Areas were properly posted and controlled. The inspectors observed radiation worker activities, while exiting contaminated areas, and noted use of good health physics practices.
All portable RP survey instrumentation observed were properly calibrated and source response checked in accordance with RP procedures.
Surveys On April 1,1998, the inspectors atten@d a radiation protection supesvisor shift tumover meeting. During that meeting,Ine radiation protection staff discussed a task in which four personnel contamination events occurred during installation of rigging on the polar crane rail to support work for the purge valve replacement in Unit i reactor building.
Three of the four personnel contamination events involved low-level, facial
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contamination, approximately 200-300 counts per minute. The other contamination was low level nonfacial. Whole-body counts performed for the three individuals revealed that all personnel were well below the licensee's action level of 10 millirems for recording intemal dose. Upon review of Radiation Work Permit 1-1998-1071, Revision 'O, (which was used by these individuals), the inspectors noted that the work area where the workers were contaminated was not listed Upon further review, the inspectors determined that no survey had been conducted to determine the radiological conditions and controls prior to the workers entering this area. In discussion with radiation protection supervision, the inspectors were informed that the failure to perform a survey was a result of miscommunication between the craft workers and health physics staff
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-12-involving the location of the actual work area. A survey performed of the work area after the above contamination events revealed that smearable contamination was as high as
400,000 dpm/100cm,
Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e.2, includes procedures for radiation surveys. Section 6.1.8.a of Procedure 1000.031, " Radiation Protection Manual," states, in part, "that ANO radiation protection performs surveys to identify and control the sources of radiation, contamination and j
airborne radioactivity." The failure to perform a survey to evaluate the radiological hazards present prior to allowing individuals to work in area is considered a violation of Technical Specification 6.8.1.a (50-313/9813-03).
Falsified Survev Information On September 4,1997, the licensee reported to the NRC senior resident inspector that they identified on August 2,1997, that a senior health physics technician had falsified conducting radiation and contamination surveys of the NRC resident inspector's office, central alarm station and the secondary alarm station areas. During a supervisory review of the survey docurrentation the licensee determined that the survey records were falsified since the te:,hnician who documented the above surveys did not have access to the areas documented. On September 5,1997, the licensee terminated the senior health physics technician's employment.
Following discovery that above surveys were inaccurate, the licensee promptly performed a subsequent survey of all areas in question. Additionally, the licensee reviewed previous survey documentation performed by the senior health physics technician who had falsified the survey documentation. This review identified no other survey discrepancies.
i This event was documented on September 4,1997, in Condition Report C-97-0203. The inspectors reviewed Condition Report C-97-0203 during the inspection and noted that appropriate and timely corrective action had been taken by the licensee.
10 CFR 50.9 states, in part, that information required by license conditions to be maintained by the licensee to be complete and accurate in all material respects.
Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of J
Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e.2, includes procedures for radiation surveys. Section 6.4.1.B of Procedure OP 1012.018, " Administration of Radiological Surveys," Revision 3, states,
" Complete all survey documentation accurately and legibly using black ink."
l The inspectors noted that the licensee identified the issue during the review and approval process, and determined that the survey documentation was not approved as a complete record. Therefore, the inspectors determined a violation of 10 CFR 50.9 had not occurre t 1.
l-13-Tours During tours of both Unit 1 and Unit 2 auxiliary and fuel storage buildings, the inspectors noted that area radiological surveys were posted outside each room / area which accurately reflected radiological conditions and postings in those areas observed by the inspectors. The inspectors determined that, in general, these surveys were documented in a clear and consistent manner and were easy to read and understand.
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. Conclusions Radiation protection technicians assigned to monitor personnel exiting the radiological controlled area were knowledgeable of appropriate actions to take regarding the handling of personnel contamination events and release of material from the radiological controlled acea. Good controls were in place to prevent the spread of radioactive contamination. In general, radiological surveys were documented in a clear consistent manner and were easy to read and understand. A violation was identified for the failure to perform a radiological survey prior to workers installing rigging on the polar crane resulting in four personnel contamination events. The failure to survey was a result of mis-communications between the craft workers and health physics staff involving the location of the actual work area.
R1.5 Maintainino Occuoational Exoosure As Low As is Reasonably Achievable (ALARA)
a.
Insoection Scone (83750)
Radiation protection personnel involved with the ALARA program were interviewed. The following areas were reviewed:
ALARA committee support
Exposure goal establishment and status
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Temporary shielding program
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Chemistry controls
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b.
Observations and Findings The inspectors noted that the ALARA committee was properly supported by all major work groups. Department, and individual radiation work permit exposures were appropriately tracked and trended by ALARA personnel.
A review of exposure history concluded that the station's person-rem exposure continued to trend downward. The inspectors noted that the person-rem exposure for 1997 was 117, which was the lowest yearly person-rem exposure in the operational history of the Arkansas Nuclear One.
I The Unit 1 outage exposure goal was 130 person-rem. The inspectors noteo a good use
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of past outage data for evaluating trends in radiation exposures for specific routine
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-14-outage activities, and noted that outage exposure goal was challenging and set based on i
past best performance.
A review of the shutdown chemistry controls revealed that 2000 curies were projected to be removed from the reactor coolant using a hydrogen peroxide chemical flush in conjunction with the letdown demineralizer filter system. The inspectors were on site during the chemical flush and noted that general area exposure rates were reduced approximately 5 percent; however, this process and results were not completed during the inspection.
The inspectors noted that a good temporary shielding program was in place. The licensee projected a dose savings of approximately 40 person-rem from the use of temporary shielding.
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Conclusions Overall, an effective ALARA program was implemented. The ALARA committee was properly supported by all major work groups. Outage exposure goals were challenging.
The person-rem exposure for 1997 of 117 was the lowest person-rem exposure in the operational history of the Arkansas Nuclear One.
R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Radiation Protection Procedure Review a.
Insoection Scoce (83750)
Selected radiation protection procedures related to the areas of inspection were reviewed for adequacy and consistency with the requirements of 10 CFR Part 20.
b.
Observations and Findings During review of selected radiation protection procedures, the inspectors noted that Section 6.1.3 of Procedure 1012.018, " Administration of Radiological Survey, " states that, "All surveys should evaluate potential hazards present." Procedure 1012.006,
" Radiation Protection Procedures," Revision 3, discusses words used to depict requirement levels. Attachment 4 provides the meaning of procedural words, "Shall" is defined as an essential action, "Should" is defined as a recommendation.
Technical Specification 6.10 (Unit 1)/6.11 (Unit 2) states, in part, that procedures shall be prepared consistent with the requirements of 10 CFR Part 20.10 CFR 20.1501(a)
states, in part, that "each licensee shall make or cause to be made, surveys that are reasonable under the circumstances to evaluate, the potential radiological hazards that could be present." The failure to prepare procedures consistent with the requirements of 10 CFR Part 20 is considered a second example of a violation of Technical Specification 6.10/6.11 (50-313;-368/9813-02).
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Conclusions A second example of a violation of Technical Specifications 6.10/6.11 was identified i
involving the failure to maintain procedures consistent with 10 CFR Part 20 l
requirements. Specifically, a radiological survey procedure in which the word "should" was used in lieu of "shall" as required by 10 CFR 20.1501(a).
R5 Staff Training and Qualification in Radiological Protection and Chemistry RS.1 Radiation Protection Staff Trainina a.
Insoection Scooe (83729)
Personnel involved with contractor radiation protection technician training and resume evaluation were interviewed. The following items were reviewed:
Radiation protection technician training lesson plans
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Resumes of contractor radiation protection technicians
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Radiation protection management oversight of the training program
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b.
Observations and Findintjs The inspectors noted that appropriate topics were covered for assigned outage tasks in the training schedule. Lesson plans were well developed, and radiation protection managem.:,nt was appropriately involved in developing the topics. Site and industry lessons learned were included in the training program.
The licensee utilized a contractor organization for temporary radiation protection technician outage support. Twenty-two contractor senior radiation protection technicians j
were hired to support cutage radiological activities. All contractor senior radiation protection technicians met, or exceeded, the requirements of American Nuclear Standard Institute 3.1 (3 years of radiation protection experience).
j The contractor senior radiation protection technicians were tested on site-specific material. The inspectors noted that the Northeast Utilities screening program was used to evaluate the general radiological knowledge of the contractor senior radiation protection technicians brought on site to support outage activities. The Northeast Utilities
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l program has been recognized and approved by a number of utilities as an acceptable method to evaluate a radiation protection technic;an's general radiological knowledge.
On-the-job training and evaluation qualification programs utilized during the contractor
senior radiation protection technician training program were reviewed. The inspectors determined that the tasks were appropriate, and the training and evaluation guidelines were clear. Station radiation protection management was appropriately involved in the development of these programs.
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Conclusions Contractor senior radiation protection technician training and qualification programs were effectively maintained. Station radiation protection management was appropriately involved in the development and monitoring of these programs.
R6 Radiological Protection and Chemistry Organization and Administration The inspectors reviewed the present organization chart and compared it to an J
organization chart obtained during the previous inspection. No major changes were identified. The licensee maintained an appropriate organization to effectively implement the radiation protection program.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Audits and Surveillances. and Radiation Deoartment Self-Assessments and Radioloaical Condition Reoorts
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a.
Insoection Scoce (83729)
Selected personnel involved with the performance of quality assurance audits and surveillances and radiation department self-assessments were interviewed. The following items were reviewed:
Quality assurance audits performed since November 1997
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Quality assurance surveillances performed since November 1997
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Radiation protection department self-assessments performed since November
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1997 Radiological condition report written since November 1997
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b.
Observations and Findinos Quality assurance audit (QAP-3-98) was completed at the time of the inspection; however, the audit report was in draft and not ready for review.
One operational radiation protection-based quality assurance sumeillance was performed since the last inspection in November 1997. This surveillance focussed on radiological postings. This surveillance was insightful, thorough, and provided management a good overview of the area reviewed. One recommendation and three observations were documented. The inspectors reviewed the corrective actions pertaining to the one recommendation and determined it to be appropriate and timely to correctly address the issue.
I The radiation protection area inspection program (department self-assessments) and schedule of activities were reviewed. Additionally, the inspectors reviewed selected area inspection reports at random. The inspectors determined that the reports were clearly I
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-17-documented and provided radiation protection management with a good tool to use to assess and improve the radiation protection program.
Selected radiological condition reports were reviewed. The inspectors determined that recommendations to prevent a recurrence appeared to be appropriate and, in general, corrective actions were closed out in a timely manner. No negative trends were identified by the inspectors during this review.
c.
Conclusions One operational radiation protection-based quality assurance surveillance was performed and provided management a good overview of the area reviewed.
Radiological condition report recommendations to prevent a recurrence appeared to be appropriate and, in general, corrective actions were closed out in a timely manner. No negative trends were identified with radiological condition reports.
R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 (Discussed) Violation 50-313/368/97-15-01: Failure to follow radiation work cermit reouirements The inspectors reviewed the corrective actions described in the licensee's response letter dated August 11,1997, and noted that, although the actions described in the response letter were complete, they do not appear to have been effective in resolving the issue. This item will remain open pending the review of the corrective actions of a similar violation identified in this inspection report.
R8.2 (Closed) Violation 50-313/368/97-19-01: Failure to orocerly store a 5-millicurie source _in a designated area i
The inspectors verified the corrective actions described in the licensee's response letter i
dated December 3,1997, were implemented.
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V. Management M._getinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting on April 3,1998. The licensee acknowledged the findings presented.
No proprietary information was identified.
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ATTACHMENT
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PARTIAL LIST OF PERSONS CONTACTED Licensen R. Hutchinson, Vice President, Operations G. Ashley, Licensing Supervisor R. Bement, Radiation Protection / Chemistry Manager M. Cooper, Licensing Specialist S. Cotton, Training /EP Director i
D. Fowler, Quality Assurance Supervisor
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l D. Mims, Licensing Director A. South, Licensing Specialist
J. Smith, Radiation Protection Superintendent J. Vandergriff, Quality Assurance Director NRC K. Kennedy, Senior Resident inspector P. Alter, Project Engineer, Region IV INSPECTION PROCEDURE USED i
83729 Occupational Exposure During Outages LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED Ooened 50-313/9813-01 VIO Failure to follow radiation work permit procedural requirements to determine the expected radiological conditions.
50-313/368/9813-02 VIO Failure to maintain procedures consistent with the requirements of 10 CFR Part 20.
50-313/9813-03 VIO Failure to perform a survey.
C!QSAd 50-313/368/9719-01 VIO Failure to properly store a 5 millicurie source in a designated area.
Discussed 50-313/368/9715-01 VIO Failure to follow radiation work permit requirements I
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LIST OF DOCUMENTS REVIEWED Procedure 1000.031, " Radiation Protection Manual," Revision 18
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Procedure 1012.017. " Radiological Posting and Entry / Exit Requirements," Revision 5 Procedure 1012.018, " Administration of Radiological Surveys," Revision 3 Procedure 1012.019. " Radiological Work Permits," Revision 6 Procedure 1012.027, "ALARA Program," Revision 2
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Procedure 1601.209, "Whole Body Counting / Bioassay," Revision 6 Procedure 1601.301, " Radiological Surveys," Revision 5 Quality Assurance Surveillance Report 058-97, " Radiological Postings" l