IR 05000313/1998019
| ML20195F217 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20195F203 | List: |
| References | |
| 50-313-98-19, 50-368-98-19, NUDOCS 9811190214 | |
| Download: ML20195F217 (13) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-313 50-368 l
License Nos.:
. NPF-6 Report No.:
50-313/98-19 50-368/98-19 Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Units 1 and 2 Location:
Junction of Hwy. 64W and Hwy. 333 South Russelville, Arkansas Dates:
October 19-22,1998 inspector (s):
Michael C. Hay, Radiation Specialist, Plant Support Branch
Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety
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Attachment:
Supplemental Information
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2-EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 l
NRC Inspection Report 50-313/98-19; 50-368/9819 This announced, routine inspection reviewed the radiation protection program. The inspection focused on exposure controls, control of radioactive materials and contamination, surveying and monitoring, and quality assurance oversight of the radiation protection program, i
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Plant Suocort Implementation of the external and internal exposure control programs was good. An
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outstanding radiation worker training course was developed to improve radiation worker knowledge. Workers were knowledgeable of work area radiological conditions and controls. Radiological controlled areas were posted and controlled properly. Radiation survey information was current and accurate. A good calibration and response test program was maintained for radiation survey instruments and the whole-body counters.
In general, housekeeping within the radiological controlled areas was good.
(Sections R1.1 and R1.2).
Overall, an effective and aggressive ALARA program was implemented. The 1997
3-year average dose of 118 person-rem was belew the PWR national average of 144 person-rem. The projected 1998 3-year average dose of 82 person-rem indicates an improving trend (Section R1.3).
Overall, an effective quality assurance audit program was implemented. One health
physics quality assurance audit and two surveillances were completed since April 1, 1998. The quality assurance audit was considered exceptional and provided management a good assessment of the health physics program. Audit findings were included in the corrective action program. Timely corrective actions were implemented for audit findings (Section R7.1).
Condition Report CR-ANO-1-1998-0475 pertaining to health physics personnel failing to
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survey exhibited weak corrective actions and lacked documented evidence to support that all corrective actions were performed. No violation was issued for the failure to survey because open corrective actions from a previous NRC violation should reasonably prevent a recurrence (Section R7.2).
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-3-Report Details IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Exoosure Controls a.
Inspection Scoce (83750)
The inspector interviewed radiation protection personnel and reviewed the following:
Radiological controlled area access controls
Radiation work permits
Control of high and locked high radiation areas
Radiological posting
Radiation protection job coverage
Dosimetry use
Housekeeping within the radiological controlled area
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Observations and Findinas The inspector determined that an effective program was in place to properly control access into the radiological controlled areas. All active radiation work permits were displayed at the radiological controlled access point. The inspector reviewed selected radiation work permits and found them informative, comprehensive, and provided radiolo0 cal conditions and controls to protect and inform the worker. All radiation i
workers questioned by the inspector were knowledgeable of their radiation work permit requirements and knew to contact health physics personnelif their electronic dosimeter alarmed.
During tours of the radiological controlled area, the inspector observed that high radiation areas were properly posted and controlled. All Technical Specification high radiation area doors observed were verified locked or properly controlled.
The inspector observed radiation protection oversight of work activities within the radiological controlled area and determined that the radiation protection technicians provided proper instruction and assistance to radiation workers.
The inspector noted that all radiation workers observed in the radiological controlled area wore dosimetry devices appropriately. Thermoluminescent dosimeters were processed by a National Voluntary Laboratory Accredited Program.
The inspector noted that, in general, housekeeping within the radiological controlled area was good, c.
Conclusions
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Radiation exposure controls were good. Workers were knowledgeable of the work area radiological conditions and controls. Radiological controlled areas were posted properly.
High and locked high radiation areas were properly controlled. Radiation protection technicians provided good oversight of work activities. in general, housekeeping within the radiological controlled area was good.
R1.2 Control of Radioactive Material and Contamination: Surveyina and Monitorina a.
Inspection Scoce (83750)
The inspector interviewed radiation protection personnel and reviewed the following:
Radioactws contamination controls
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Radioactive source accountability
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Personnel contamination events a
Radiological survey records
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Portable survey instrument calibration
Whole-body counter calibration a
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Qbservations and Findinas The inspector observed radiation work practices in contaminated areas and identified no deficiencies. Radiological contamination survey instruments and personnel contamination monitors were properly used by workers exiting contamination areas.
The inspector reviewed the personnel contamination log and found no discrepancies.
The inspector was informed that approximately 400 personnel contamination events were recorded at the facility since January 1,1998. Of these events, one resulted in a personnel dose evaluation due to a hot particle identified on a person's forearm. The evaluation was reviewed by the inspector and found to be appropriately conducted using an industry accepted computer code. The personnel dose was properly recorded on the individuals exposure record, NRC Form 5.
The inspector determined that actions had been taken to reduce the number of personnel contamination events and control of radioactive materialissues. An improved radiation worker training program was developed. The new program focused on performance-based activities. Six radiological controlled mock-up areas were established for radiation workers to practice planned work ectivities. These tasks included working in overheads where high iadiation areas were accessible, contaminated areas, and areas where temporary shielding needed to be moved or utilized to reduce personnel dose. The inspector was informed that all site radiation workers, along with contract employees, will be required to attend the training prior to
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the next outage scheduled for January 1999. The inspector noted that the licensee had devoted significant resources into improving radiation worker knowledge.
A review of the licensee's control of contamination areas was performed. Approximately 6 percent of Unit 1 and 3 percent of Unit 2 radiological controlled areas were identified l
as contamination areas. The inspector determined that a concerted effort was in place
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to evaluate and prioritize contaminated areas in the plant for decontamination.
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-5-The inspector reviewed the licensee's source inventory and source leak check records.
No deficiencies were noted. Source identification numbers were randomly selected by the inspector and were confirmed to be properly stored as indifed on the inventory.
The inspector randomly reviewed radiological survey records and survey maps. Survey documentation was complete and easy to understand. The inspector performed independent radiation surveys of selected areas, and confirmed that survey data was accurate. The inspector reviewed air sampling records performed by radiation protection technicians during the month of October 1998 and noted no deficiencies.
The inspector reviewed calibration and response test records for portable radiation detection instruments, small article monitors, and personnel contamination monitors. All radiation detection instrumentation reviewed had been calibrated within the specified interval and properly response checked.
Calibration records for the licensee's whole-body counters were reviewed. Calibrations were performed by an outside contractor within the required frequencies using NIST traceable sources. The inspector noted that the lowest gamma energy used during whole-body counter calibrations was 356 kev (kiloelectron volt). The inspector commented that the energy calibration may not identify low energy gammas below 356 kev. The licensee acknowledged this observation and responded that an evaluation would be performed to ensure that the whole-body counter calibrations adequately accounted for the significant gamma energies present in the plant.
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Conclusions Overall, an effective contamination area control program was being implemented. An outstanding radiation worker training course was developed to improve radiation worker knowledge. Radiation survey information was current, accurate, and easy to understand. A good calibration program was maintained for radiation detection instrumentation and whole-body counters.
R1.3 Maintainino Occupational Exposure As Low As is Reasonab!v Achievable (ALARA)
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Inspection Scoce (83750)
Radiation protection personnelinvolved with the ALARA program were interviewed. The following areas were reviewed:
Outage exposure goal establishment and status
Site exposure goal establishment and status
Dry fuel transfer to storage casks
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Observations and Findinas Station, department, and individual radiation work permit exposures were appropriately tracked and trended by the ALARA group. The inspector noted that site average person-rem for 1998 was on track to be below the site per unit goal of 96 person-re.
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The site ALARA group projects site average dose for 1998 to be approximately 86 person-rem. The 1997 3-year average dose of 118 person-rem was below the PWR national average of 144 person-rem. The projected 1998 3-year average dose of 82 person-rem indicates an improving trend.
The inspector reviewed the ALARA report for the 1R14 refueling outage. The outage person-rem of 124 was lower than the projected 130 person-rem. The inspector noted that the major contribution for dose savings during outage 1R14 resulted from using multiple tool manipulators during steam generator channel head maintenance. This practice reduced personnel projected dose by nearly one-half of its original dose estimate.
The licensee performed several initiatives to reduce personnel doses during future outages. These initiatives included refurbishing the reactor basement floor, installation of permanent lead shielding, and steam generator upper platforms.
Refurbishing the reactor basement floor significantly reduced the dose rates in the reactor basement. In 1980, the licensee experienced a radioactive liquid spill on the reactor basement floor which produced gamma dose rates up to 25 millirem per hour and beta dose rates up to 2.4 rad per hour. The refurbishment consisted of removing the top layer of concrete from the reactor building floor followed by resurfacing with a light colored paint to improve lighting conditions. This effort was extended beyond its original scope due to the excellent results obtained. The refurbishment eliminated the beta dose rates and reduced the gamma dose rates up to 50 percent.
Permanent lead shielding installed on the reactor drain header piping reduced gamma dose rates form 40 millirem per hour down to 10 millirem per hour. The licensee estimates this modification to reduce future outage doses by approximately 3.2 rem.
Other activities performed by the licensee to reduce personnel dose included:
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installation of permanent platforms for upper steam generator work,22 system flushes to reduce high gamma dose rates from piping, and use of over 40,000 pounds of temporary shielding to reduce localized hot spots.
During the inspection, the transfer of spent fuel from the spent fuel pool to dry cask
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storage was being performed. The inspector noted that the facility has performed six spent fuel transfers to dry cask storage. The inspector noted that good ALARA practices were utilized during the evolution. These practices included keeping the spent fuel storage container submerged in a shielded enclosure, and the use of temporary lead shielding to reduce local radiation levels in work areas.
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Conclusions Overall, an effective and aggressive ALARA program was implemented. The 1997 3-year average dose of 118 person-rem was below the PWR national average of 144 person rem. The projected 1998 3-year average dose of 82 person-rem indicates an improving tren.
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-7-R5 Staff Training and Qualifications l
l R5.1 Radiation Protection Staff Qualifications l
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Insoection Scope (83750)
The inspectors reviewed the qualifications of the new radiation protection manager.
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Observations and Findinas Due to a recent staff change, a new individual was designated to fill the radiation protection manager position. Technical Specification 6.3.1 requires that the individual filling the position of radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. From a review of the new radiation protection manager's resume, the inspector determined that this individual satisfied the requirements of Technical Specification 6.3.1.
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Conclusions The new radiation protection manager satisfied the requirements of Technical Specification 6.3.1.
R7 Quality Assurance in Radiation Protection Activities i
R7.1 Quality Assurance Audits and Surveillances a.
Insoection Scope (83750)
Quality assurance audits and surveillances performed since April 1,1998, were reviewed.
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Observations and Findinas Quality Assurance Audit Report OAP-3-98 was reviewed. This audit assessed the effectiveness and implementation of the health physics program. The overall results of the audit indicated that the health physics program was being implemented satisfactorily. The inspector noted that the audit was probi1g and comprehensive. Six findings, five recommendations, and four observations were identified resulting in six condition reports being issued. The inspector reviewed the condition reports developed
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as a result of this audit and noted that proper corrective actions were implemented in a timely manner.
Individuals involved in the audit had strong auditing backgrounds including both technical and operational health physics experience. One member of the auditing team was a specialist from another Entergy site. Overall, the audit provided management a good assessment of the health physics progra,.
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8-The inspector reviewed two quality assurance radiological surveillances. These assessments reviewed several radation protection program elements including control,
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handling and move /nent of radioactivs material and radiation worker knowledge with i
respect to requirements contained in their radiation work permits. The inspector found these surveillances adequately assessed the areas reviewed, c.
Conclusions e
Overall, an effective quality assurance audit program was implemented. One health physics quality assurance audit and two surveillances were completed since April 1, 1998. The quality assurance audit was considered exceptional and provided management a good assessment of the health physics program.
R7.2 Condition Reports a.
Insoection Scope (83750)
Selected radiological condition reports developed since April 1,1998. were reviewed.
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Observations and Findinas i
The inspector reviewed an index of all radiological condition reports written since April 1, 1998, and determined that the licensee identified items at the proper threshold to provide management with a good overview of the radiation protection program. In general, corrective actions were appropriate and conducted in a timely manner to reasonably prevent a recurrence, with the following exceptien.
Condition Report CR-ANO-1-1998-0475 written on May 5,1998, and closed on June 16, 1998, documented that internal parts were removed from two valves contained in an identified potentially contaminated system outcide the controlled access area without health physics personnel performing a radiological survey to establish the radiological conditions and controls.
During review of this event, the inspector was informed that the maintenance mechanic performing the work on the valves had informed a health physics technician prior to breaching the potentially contaminated system as required by the radiation work permit.
The maintenance mechanic stated that the health physics technician allowed the breach of the potentially contaminated system without performing any radiological surveys to establish the radiological conditions and controls. Consequently, the system was breached, and valve components were placed in buckets. Approximately three days later, a maintenance supervisor noted that the material in the buckets was not located in a posted radioactive material storage area as in the past. The maintenance supervisor then notified health physics personnel. Subsequently, surveys were performed indicating the valve intemals in the buckets had up to 80,000 disintegrations per minute.
Health physics personnel then established proper controls for the material.
The following corrective actions were documented in Condition Report CR-ANO-1-1998-0475:
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The maintenance mechanic met the expectations for following the radiation work permit, however, perhaps the maintenance mechanic could have insisted that the parts be surveyed.
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This condition report will be discussed with the maintenance shop and will be covered during lessons learned sessions.
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The Superintendent of unit one mechanical maintenance and the superintendent of radiation protection will discuss this event and decide if any further actions need to be issued.
In reviewing the first corrective action, the inspector questioned the radiation protection manager if it was a reasonable expectation for a maintenance mechanic, who is not trained as a health physics technician, to have insisted that health physics perform a radiological survey. The radiation protection manager stated that this was not a reasonable expectation and that the health physics department should be held responsible for ensuring that radiological surveys are performed to establish j
radiological controls to protect the worker.
j in reviewing the second corrective action, interviews with the maintenance mechanic (who was involved in breaching the potentially contaminated system) and a maintenance mechanic supervisor were conducted. The inspector questioned them whether they had received training or been informed of lessons learned from this event. They both responded no, but they could not recall any information being presented in relation to this event.
In reviewing the third corrective action, interviews with the superintendent of radiation protection were conducted to determine what further actions were identified to address the failure of health physics to survey the potentially contaminated material. The
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superintendant of radiation protection (currently the radiation protection manager) stated that he was not involved in any discussions concerning this event and was not familiar with the details of this particular event until the inspector brought it to his attention.
Later, in discussion with the Unit 2 plant manager (who was the radiation protection and chemistry manager during this event in May 1998) the inspector was informed that he
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had held a discussion with the superintendent of mechanical maintenance. The inspector noted, however, that the condition report contained no information concerning what further actions were decided upon to resolve the event. The inspector questioned if the health physics department was informed of the event. The Unit 2 plant manager believed the event was discussed during the health physics department"s morning shift turnover after the event was discovered. In review of turnover records, the inspector noted that this event was documented; however, in discussion with the health physics staff, only those health physics personnel directly involved in surveying the material in the buckets or writing of the event condition report recalled being informed.
in further discussions, the licensee stated that, although the root cause of the event involving the failure to survey was not documented in the condition report, it was determined that miscommunications between the maintenance mechanic and health
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-10-physics personnel were speculated. Tne inspector was informed that the root cause was speculated because the health physics technician involved in the failure to survr,y had left site, and no attempt was made to contact him,
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i The inspector determined that Condition Report CR-ANO-1-1998-0475 failed to ckarly identify a root cause and failed to clearly document the actions performed. It was also determined that corrective actions were not effectively implemented.
NRC Inspection Report 50-313/368-9813 identified a violation (9813-03) involving the failure to survey due to miscommunications between maintenance and health physics personnel. Corrective actions for this violation were still not complete. The inspector reviewed these open corrective actions and determined that they were reasonable actions to prevent a recurrence for the failure to sunley identified during this inspection.
l Procedure 1601.301, " Radiological Surveys," Revision 5, Section 6.2.3, states, in part,
" Survey the internal portions of components with contaminated or potentially contaminated internal areas during disassembly." The inspector determined that the licensee failed to survey the internal components of the potentially contaminated components due to miscommunications between the maintenance mechanic and health physics personnel. This violation is similar to the violation identified in NRC Inspection Report 50-313/368/9813-03. However, no cited violation will be issued for the failure to survey discussed above because open corrective actions for violation 9813-03 should reasonably prevent a recurrence.
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Condition Report CR-ANO-1-1998-0475 pertaining to health physics personnel failing to survey exhibited weak corrective actions and lacked documented evidence to support
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that all corrective actions were performed. No violation is being considered for the failure to survey because open corrective actions from a previous NRC violation should reasonably prevent a recurrence.
R8 Miscellaneous Radiological Protection and Chemistry issues (Inspection Scope 92904)
R8.1 (Closed) Violation 50-313:-368/9715-01: Failure to Follow Radiation Work Permit Reauirements and Locked Hiah Radiation Control Point Duties NRC Inspection report 50-313/368-98-13 stated, in part, that corrective actions described in the licensee's response letter dated August 11,1997, were complete; however, they did not appear to have been effective in resolving the issue. The report also stated that this item will remain open pending the review of the corrective actions of a similar violation identified in NRC Inspection Report 50-313/368-98-13. The inspector verified the corrective actions described in the licensee's response letter dated May 14, 1998, were implemented.
R8.2 (Closed) Violation 50-313:-368/9803-03: Failure to Uodate Radioloaical Survey Maps
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-11-i The inspector verified the corrective actions described in the licensee's response letter
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dated May 18,1998, were implemented.
Ni R8.3 (Closed) Violation 50-313:-368/9813-01: Failure to Follow Radiation Work Permit Reauirements for Radioloaical Conditions The inspector verified the corrective actions described in the licensee's response letter dated May 14,1998, were implemented.
R8.4 - (Closed) Violation 50-313:-368/9813-02: Failure to Maintain Procedures Consistent With 10 CFR Part 20 The inspector verified the corrective actions described in the licensee's response letter i
dated May 14,1998, were implemented.
I V. Manaaement Meetinas X1 Exit Meeting Summary
' The inspector presented the inspection results to members of licensee management at an exit meeting on October 22,1998. The licensee acknowledged the findings
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presented. No proprietary information was identified.
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ATTACHMENT
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Supplemental Information PARTIAL LIST OF PERSONS CONTACTED Licensee G. Ashley, Licensing Supervisor B. Bement, Plant Manager, Unit 2 T. Chilcoat, Radiation Protection Superintendent M. Cooper, Licensing Specialist R. Hutchinson, Vice President D. James, Manager, Nuclear Safety B. McKelvy, Technical Specialist / Radiation Protection and Chemistry W. Perks, Manager, Radiation Protection and Chemistry
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S. Pyle, Licensing Specialist J. Smith, Radiation Protection Manager J. Vandergrift, Director, Nuclear Safety NRC Kriss Kennedy, Senior Resident inspector Stephen Burton, Resident inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure 92904 Follow Up - Plant Support LIST OF ITEMS OPENED AND CLOSED Closed 50-313;-368/9715-01 VIO Failure to Follow Radiation Work Permit Requirements and Locked High Radiation Control Point Duties 50-313;-368/9803-03 VIO Failure to Update Radiological Survey Maps 50-313;-368/9813-01 VIO Failure to Follow Radiation Work Permit Requirements for Radiological Conditions 50 313;-368/9813-02 VIO Failure to Maintain Procedures Consistent With 10 CFR Part 20
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2-LIST OF DOCUMENTS REVIEWED Procedure 1012.019, " Radiological Work Permits," Revision 6 Procedure 1012.018, " Administration of Radiological Surveys," Revision 3 Procedure 1012.017, " Radiological Posting and Entry / Exit Requirements," Revision 5 Procedure 1000.031, " Radiation Protection Manual," Revision 18 Procedure 1601.301, " Radiological Surveys," Revision 5 Procedure 1000.104," Condition Reporting and Corrective Actions," Revision 14 Procedure 1601.209, "Whole-Body Counting / Bioassay," Revision 6 A summary of radiological condition reports written between April 1 and October 19,1998.
Quality Assurance Audit Report OAP-3,1998," Health Physics," Revision 3 l
Quality Assurance Surveillance Report SR-014-98,"Radwaste Group RAM Control / Material
Release (CA-1 and OCA)"
Quality Assurance Surveillance Report SR-013-98,"RWP Compliance Outside Controlled Access"
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" Arkansas Nuclear One 1R14 ALARA Report," 1998
" Unit 1 Monthly Area Contamination Report," September 1998
" Unit 2 Monthly Area Cantamination Report," September 1998
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