IR 05000331/1998019
| ML20198J820 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198J803 | List: |
| References | |
| 50-331-98-19, NUDOCS 9812300268 | |
| Download: ML20198J820 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGIONlli l l ,
I Docket No: 50-331 i
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License No: DPR-49
! Report No: 50-331/98019(DRS)
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l Licensee: Alliant, IES Utilities In Facility: Duane Arnold Energy Center i
Location: Palo, Iowa '
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Dates: November 30 - December 4,1998 -
l- Inspectors: Steven K. Orth, Senior Radiation Specialist
! Mark Mitchell, Radiation Specialist I Andrea L. Kock, Radiation Specialist j Approved by: Gary L. Shear, Chief, Plant Support Branch 2 I
Division of Reactor Safety i l
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9812300268 981223 PDR ADOCK 05000331 G PDR
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. EXECUTIVE SUMMARY O=ne Arnold Energy Center, Unit 1 I NRC Inspection Report 50-331/98019 I This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) and chemistry programs. Specifically, the inspection consisted of a review of the implementation of the liquid and gaseous radioactive effluents program, which included a review of offsite dose commitments, process radiation monitor calibrations, i engineered safety feature ventilation testing, and self assessments. In addition, the inspectors reviewed the internal and external exposure control programs, which included administrative controls, air sampling, and dose assessments. The report covers a one-week inspection ;
concluding on December 4,1998, performed by three radiation specialists. No violations of regulatory requirements were identifie Plant Support i
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o The licensee continued to effectively implement administrative external dose controls to ensure that personnel doses were maintained as-low-as-is-reasonably-achievable l I
(ALARA). Personnel doses were maintained in accordance with the established administrative controls and were below the limits contained in 10 CFR Part 20, and the dose to the embryo / fetus of declared pregnant women were also maintained below the limits of 10 CFR Part 20. In addition, the RP staff effectively evaluated a bias between thermoluminescence dosimeter and electronic dosimeter results and was completing actions to correct the problem. (Section R1.1) )
o The inspectors observed some problems with the approvals for personnel authorized to exceed administrative dose controls. While the RP staff maintained the records of dose upgrades and the appropriate level of supervision approved the upgrades, the i justification for the upgrades was not consistently documented. (Section R1.1) l l
o The licensee effectively implemented the internal dosimetry program. Radiation workers l were adequately protected from airborne radioactive contaminants, as indicated by air J
sample evaluations and the radiological survey program. The RP staff had performed ;
and maintained an acceptable evaluation which concluded that forn al internal monitonng was not required. Specifically, radiation workers were effectively monitored for internal deposition of radioactive material via the passive monitoring program, with the portal contamination monitor alarm setpoints set to indicate intakes of 1 to 2 percent of an annual limit on intake. (Section R1.2)
l o The licensee properly implemented the air sampling program. Air sampling equipment i was properly calibrated and maintained. Based on air sample results, the licensee also employed a sound program to determine if respirators were required. (Section R1.3)
l l o The 1996 and 1997 Annual Radioactive Material Release Reports and Annual Environmental Reports were well written and demonstrated that radioactive effluents were maintained below regulatory limits. The licensee continued to release only 2 l l
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ALARA principle. The inspectors also found that the RP staff's offsite dose calculations ;
were properly performed. (Section R1.4)
o The inspectors noted that the licensee effectively maintained internal dosimetry monitoring equipment and that individuals who had received intakes of radioactive ;
material were accurately assigned an appropriate committed effective dose equivalen The RP staff demonstrated acceptable competence in using the equipment and making correct assessments with the data. (Section R2.1)
o Overall, the maintenance and testing program for the standby gas treatment system and standby filter units (i.e., control room ventilation filtration systems) were effectively implemented. The licensee performed system testing in accordance with Technical Specification requirements, and test results indicated acceptable system performanc The licensee also identified and promptly resolved maintenance and operability issue (Section R2.2) The licensee properly maintained effluent and process radiation monitors. For example, the system engineer trended system performance and identified high frequency failure modes, which were being corrected. In addition, the staff performed radiation monitor calibrations, as required by the licensee's Technical Specifications and Offsite Dose Assessment Manual. (Section R2.3)
o The inspectors observed some problems concerning the stability of the radiation monitors. During routine calibrations of final effluent radiation monitors, the inspectors noted that the "as found" monitor indications were notably outside of the licensee's acceptance criteria. However, the staff did not evaluate this performance to determine
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the effect on annual effluent calculations or to determine the reason for the variance (Section R2.3)
o Radiation protection and chemistry personnel demonstrated acceptable performance, l while obtaining effluent samples and preparing radioactive material for transport. While replacing particulate and charcoal filters, chemistry technicians demonstrated effective analytical techniques and procedure adherence. In addition, the inspectors verified that RP surveys for a shipment of radioactive materials were properly performed. (Sections R4.1 and R4.2)
o Audits of the radioactive effluent program were thorough and provided a broad review of l
the program. For example, the auditors reviewed recent changes to the program
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requirements and assessed the effectiveness of program implementation and personnel performance. Based on audit findings, the RP and chemistry staff took actions to L
correct and to enhance the program. (Section R7)
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Report Details ,
IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R External Dose Control Insoection Scooe (IP 83750) !
The inspectors reviewed the licensee's administrative external exposure controls,1997 and 1998 personnel doses, the radiation protection (RP) staff's evaluations concerning unexpected differences between thermoluminescence dosimeter (TLD) and electronic dosimeter (ED) results, and the implementation of the following procedures:
o ACP 1411.17 (Revision 8), " Occupational Dose Limits and Upgrades;" and l
o ACP 1411.18 (Revision 11), " Personnel Dosimetry." Observations and Findinas *
The inspectors verified that the licensee's TLD processing vendor maintained certification with the National Voluntary Laboratory Accreditation Program (NVLAP) and observed that the licensee maintained effective oversight of the contractor. For ,
example, the licensee routinely submitted spiked TLDs to the vendor for analysis and evaluated the vendor's results. Based on these results, the licensee maintained confidence in the vendor's quality control progra The licensee implemented administrative dose controls to ensure that personnel doses at the site were maintained as-low-as-is-reasonably-achievable (ALARA). For example, procedure ACP 1411.17 contained the following administrative dose levels for adult radiation workers: (1) a total effective dose equivalent (TEDE) of 1.0 rem in any calendar quarter and (2) a TEDE of 2.0 rem in any calendar year. With the permission of the worker's first line supervisor, a worker's dose levels could be increased to 1.5 rem TEDE per quarter and/or 3.0 rem TEDE per year. The procedure also contained
, provisions to obtain additional upgrades, with the approval of higher levels of plant I
management. However, procedure ACP 1411.17 ultimately stated that no radiation worker was allowed to receive more than 4.5 rem TEDE in any calendar year from .
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normal operation Based on the 1997 and 1998 quarterly TLD reports, the inspectors noted that the licensee maintained occupational dose to workers consistent with the requirements of 10 CFR Part 20 and the above procedures. For example, the licensee monitored three declared pregnant women and maintained the dose to the embryo / fetus in accordance with the requirements of 10 CFR 20.1208. During the gestation period, one of the three individuals obtained a dose of about 0.10 rem, which was uniform throughout the gestation period. The other two individuals did not obtain any measurable dose. In n addition, the inspectors noted that other personnel doses were generally maintained
! below the administrative dose levels described above. In 1997, all quarterly doses were l
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below the 1.0 rem dose level, and all annual doses were maintained below the 2.0 rem dose level (highest annual dose was about 1.3 rem). In the second quarter of 1998, six individuals were permitted to exceed the 1.0 rem administrative dose level. The inspectors reviewed the licensee's records for these dose level upgrades and found the approvals to be performed as required. However, the inspectors noted that the reasons for the approvals were not consistently noted on the licensee's documentation. For example, one of the forms did not document any reason, and two forms only noted the location or type of work (e.g., "drywell work" or "lSI [in-service inspection) exams").
Although not specifically required by the procedure, the RP manager indicated that the expectation was that the reason for the upgrade be clearly documented on the form to indicate its justificatio In June of 1996, the licensee replaced self reading dosimeters with EDs as secondary dosimeters. Based on the 1997 and 1998 quarterly dosimetry reports, the licensee identified a consistent, nonconservative bias between the ED and TLD results (i.e., the ratio of ED-to-TLD results ranged from 0.75 to 0.95). The licensee attributed the bias to the following:
o The ED system software was not recording and summing the doses from radiologically controlled area (RCA) entries of less than 0.001 re Consequently, the ED recorded doses for certain groups of individuals (i.e, those individuals who were completing numerous low dose entries into the RCA) were significantly lower than the doses recorded by TLD o An inherent bias in the response of the EDs (about 5 to 10 percent), which was affected by the use of hydrogen injection corrosion control (i.e., the increase in high energy gamma radiation emitted by nitrogen-16).
The inspectors discussed these issues with members of the RP staff and concluded that the staff had thoroughly evaluated the trends and were taking actions to correct the bia Conclusions The licensee effectively implemented administrative external dose controls to ensure that personnel doses were maintained ALARA. Personnel doses were maintained in accordance with the established administrative controls and were below the limits contained in 10 CFR Part 20, and the dose to the embryo / fetus of declared pregnant women were also maintained below the limits of 10 CFR Part 20. In addition, the RP staff effectively evaluated a bias between TLD and ED results and was completing actions to correct the proble The inspectors observed some problems with the approvals for personnel authorized to exceed administrative dose controls. While the RP staff maintained the records of dose upgrades and the appropriate level of supervision approved the upgrades, the justification for the upgrades was not consistently documente !
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R1.2 Internal Dosimetry Proaram l Insoection Scooe (IP 83750)
l The inspectors reviewed the licensee's internal dosimetry program. The inspectors I interviewed personnel and reviewed the following documents, which recorded the licensee evaluation for iritemal dose monitoring and provided the basis for the use of a passive monitoring program at the facility I
o " Passive Internal Monitoring Program at the DAEC Revised," NG-93-1691, dated April 21,1993; o " Prospective Evaluation of the Need for Internal Monitoring at the DAEC Revised," NG-93-1692, dated April 21,1993;
o " Periodic Evaluation on the Need for Internal Monitoring at the Duane Arnold Energy Center," Calculation No. 96-005A, NG-96-1358, dated June 18,1996; l and o Memorandum dated November 20,1998, " Preliminary Review of 10 CFR 61 Radioactive Waste Chain for Evaluation in Preparation of Conducting a Periodic Perspective Evaluation on the Need for Intemal Monitoring at the Duane Arnold Energy Center." Observations and Findinas l The licensee maintained portal contamination monitors (PCMs) (Eberline PCM-1B whole body counters) at the RP access control area, which were used to survey personnel i exiting the radiologically controlled area (RCA). The licensee also maintained additional PCMs (National Nuclear Corporation Model Gamma-10 portal monitors) at the protected area and RCA exits, which were used to detect gross contamination or diversion of radioactive material. As required by the licensee's procedures, personnel were required to use these PCMs upon exiting the RCA and the protected are In 1993, the licensee performed an evaluation to determine if the PCMs provided effective monitoring for intemally deposited radioactive material (i.e., passive monitoring) and to determine if monitoring for internal exposures was necessary. The RP staff tested the PCMs and determined that the detection of 1 percent of an Annual Limit on intake (All) was possible via the PCMs. In addition, the licensee determined that personnel at the facility did not need to be monitored for an internal dose based on the criteria specified in 10 CFR 20.1204. Specifically, the licensee determined that workers in every classification at the facility were not likely to receive, in one year, an intake of radioactive materialin excess of 10 percent of the All. In addition, the sensitivity of the PCMs ensured that any unplanned intake of radioactive material, which approached 10 percent of an All, would be detected. Therefore, the RP staff discontinued performing routine in-vivo bloassays (i.e., whole body counts). The NRC reviewed this determination in NRC Inspection Report No. 50-331/97013(DRS) and found the licensee's evaluation to be acceptable.
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The licensee subsequently performed a periodic perspective evaluation in 1996 (NG-96- ,
1358) to verify the ongoing validity of the 1993 determination. The methodology used in I
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the 1996 evaluation was based on evaluations of air sample data, an assessment of
- internal committed effective dose equivalent (CEDE) determinations, and 10 CFR Part s
61 radioactive waste steam evaluations. The 1996 evaluation confirmed the following: )
(1) personnel have not received 10 percent of an All; (2) internal evaluations performed l on workers with suspected intakes confirmed that passive monitoring (i.e., PCM alarm sensitivity) was sufficient to ensure that intakes with the potential of exceeding 10 percent of an All were properly detected and evaluated; and (3) the 10 CFR Part 61 l waste stream sample results Indicated that no substantial change in the radionuclide mix had occurred since the original prospective evaluation. In 1998, the licensee continued to review the above determinations and verified (via 10 CFR Part 61 sample results) that no substantial change in the radionuclide mix had occurred since the original I prospective evaluation. Therefore, the licensee reconfirmed that routine internal exposure monitoring was not require Conclusions l
The licensee effectively implemented the internal dosimetry program. Radiation workers '
were adequately protected from airborre radioactive contaminants, as indicated by air sample evaluations and the radiological survey program. The RP staff had performed and maintained an acceptable evaluation which concluded that fonnal internal monitoring was not required. Specifically, radiation workers were effectively monitored
' for internal deposition of radioactive material via the passive monitoring program, with the PCM alarm setpoints set to indicate intakes of 1 to 2 percent of an Al R1.3 A;c Samolina and Resoiratorv Protection
) Insoection Scooe (IP 83750)
The inspectors reviewed the licensee's respiratory protection program. The inspectors also reviewed the respiratory fit testing program and the air sampling program, as instituted by the RP staff; interviewed personnel; and verified the implementation of the following procedures:
o HPP-3102.20 (Revision 4), "ALARA Job Planning;"
o HPP-3104.08 (Revision 6), " Shift Routine Air Samples;" and ,
o HPP-3104.03 (Revision 3), " Radiological Air Sample Collection and Analysis." j Observations and Findinos The inspectors noted that the licensee did not maintain occupied areas of the plant in excess of 0.3 derived air concentration (DAC) during normal operation. During normal operation, airborne concentrations were properly assessed, and the licensee determined that respirator use was not warranted for activities performed under the majority of radiation work permits. The inspectors interviewed personnel and discussed the air sample collection methodology and procedural operations involved in air sampling and calibration of air sampling equipment. The inspectors concluded that the staff was knowledgeable and followed established procedures to perform the assigned dutie ;
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[ The inspectors also verified that sample collections and system calibrations were l
performed as require The licensee used an ALARA planning procedure to determine if and when to use respiratory protection. The inspectors reviewed the procedure with plant personnel.
l The decision to use a respirator was based on air sample data, expected airborne i
l concentrations (e.g., historical knowledge and data), availability of engineering controls, and ambient dose rates. The process provided the staff with sufficient information to make a decision based on sound ALARA principles. From 1996 to 1998, the licensee did not use respirators for radiological purposes outside of outage work, and no unexpected internal doses were attributed to the lack of respirator usage during this time. Although the licensee did attribute some internal doses to the lack of respirator use, the resultant doses were in accordance with maintaining the TEDE ALARA. The inspectors concluded that the RP staff used the proceduces properly to limit the TEDE to the workers in areas of potential airborne contamination.
l The licensee also maintained an acceptable fit testing program for all respirator applications. The inspectors reviewed the program and observed a fit test demonstration. The staff was knowledgeable in the procedures for proper fit testin The computer system used in support of the fit testing was in the process of being replaced to allow for Year 2000 compliance.
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The licensee properly implemented the air sampling program. Air sampling equipment was properly calibrated and maintained. Based on air sample results, the licensee also employed a sound program to determine if respirators were require R1.4 Control of Liouid and Gaseous Radicactive Effluents t Insoection Scope (IP 84750)
The inspectors reviewed the licensee's control of liquid and gaseous radioactive effluents released to the environment. Specifically, the inspectors reviewed the 1996
- and 1997 Annual Radioactive Material Release Reports, the 1996 and 1997 Annual L Environmental Reports, the RP staff's calculation of offsite doses, and the trending of i liquid and gaseous radioactive releases and discussed the program with members of j the RP staff.
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The 1996 and 1997 annual reports were well written and contained the information required by the Offsite Dose Assessment Manual (ODAM). In 1996 and 1997, the licensee maintained the policy of releasing only gaseous radioactive effluents to the
, environment. The inspectors reviewed the concentrations of the radioactive releases l and the associated doses, which were maintained at a fraction of the regulatory limits.
- Based on the licensee's offsite dose calculations, the .;.aximum calculated dose to the i nearest receptor from gaseous radioactive effluents was less than 0.01 millirem, which j was less than 0.1 per
- ,ent of the applicable ODAM limits.
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l The inspectors also noted that the licensee had made substantial changes to the ODAM l in 1998 ta accommodate the implementation of the improved Technical Specifications l (TS). In general, the substance of the changes consisted of revising ODAM references
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to be consistent with the revised TS and incorporating requirements which were deleted during the TS revision process. For example, the requirements for the offgas pre-treatment and post-treatment radiation monitors (i.e., calibration, testing, and l operability), which had previously been located in the TS, were added to Table 6.2-2 of the ODAM. The inspectors reviewed the changes and concluded that they did not decrease the effectiveness of effluent controls.
l The RP staff compared the site's effluent results to performance of the nuclear power industry (i.e, boiling water reactors). Based on the comparisons (i.e., quantity of iodine-l 131 and radioactive particulates released), the licensee's performance continued to be i
consistent with the best quartile of industry performance. On a monthly basis, the staff I also produced graphical plots of doses from current effluent releases (month-to-month)
to identify any anomalies in the quantities of gaseous effluents released. The inspectors noted that these trends were effective in demonstrating the effect of plant operations and maintenance on effluent releases and were used by the staff to detect and to
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mitigate system leakag The RP staff used a con,puter program to calculate the annual offsite doses from gaseous effluents, which was consistent with the ODAM. Using the annual gaseous release quantities, tho inspectors performed a confirmatory calculation (via the NRC PC-Dose computer code), which was in good agreement with the licensee's calculation The inspectors also verified that the staff had completed annual verifications of the software results (i.e., a comparison of the software calculations to manual calculations).
.in addition, the RP staff performed monthly calculations of offsite doses from radioactive ;
effluents, as required. During a review of the monthly calculations, the inspectors noted ,
some minor discrepancies concerning the use of certain dispersion factors, which were l described in the ODAM. The inspectors noted that the licensee's calculations were technically sound; however, the RP staff planned to review the applicable sections of the ODAM and to correct any ambiguities.
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i Conclusions 1 i The 1996 and 1997 Annual Radioactive Material Release Reports and Annual
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Environmental Reports were well written and demonstrated that radioactive effluents were maintained below regulatory limits. The licensee continued to release only gaseous radioactive effluents, which were maintained at a level consistent with the ALARA principle. The inspectors also found that the RP staff's offsite dose calculations were properly performed.
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R2 Status of RP&C Facilities and Equipment R Calibration and Maintenance of Internal Dosimetry Eauioment and Internal Dose Assessments Insoection Scope (IP 83750)
The inspectors reviewed the licensee's calibration and maintenance programs for the j PCMs located at the RCA exit and the protected area exit and for the whole body countt.rs. The inspectors reviewed select evaluations which determined the assigned CEDE for individuals who had received intakes of radioactive material. The inspectors also observed the use of the whole body counte Observations and Findinas
The inspectors reviewed select calibration records for the PCMs and whole body l counters and determined that the calibrations were conducted at the procedurally I required frequency. The inspectors noted that source checks of the monitors were completed on a daily basis. The RP staff also demonstrated the use and daily j calibration of the whole body counter. The staff followed the establishea procedure and j demonstrated a thorough knowledge of proper operating methods a-d screening !
analysi The inspectors also reviewed the licenseds dose assessments for intakes of radioactive material (1996 through 1998). During th;s period, only two intakes exceeded the licensee's threshold of 10 millirem for tracking and recording the CEDE. To determine the retention mode (i.e., inhalation versus ingestion), the licensee conducted a series of whole body counts with the whole body counter. The licensee then projected the intake using a vendor supplied software package and performed dose assessments using the International Commission on Radiological Prntection (ICRP) publication 30 methodology. The inspectors determined that the retention modes and the assigned internal doses were reasonable and verified that the resultant CEDES were below regulatory limit Conclusions The inspectors noted that the licensee effectively maintained internal dosimetry monitoring equipment and that individuals who had received intakes of radioactive material were accurately assigned an appropriate CEDE. The RP staff demonstrated acceptable competence in the using the equipment and making correct assessments with the dat R2.2 Enaineered Safety Feature (ESF) Filtration Testina Inspection Scope (IP 84750)
The inspectors reviewed the licensee's testing and maintenance programs for the standby filter units (SFU) located in the Control Building (i.e., filtration for the control
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room ventilation system) and standby gas treatment system (SGTS). The inspectors !
interviewed personnel and reviewed the documents used in the testing progra i i Observations and Findinas s
The inspectors walked down the control room indications, the SFUs, and the SGTS filtration units and reviewed selected SFU and SGTS surveillance records. The t inspectors verified that test results for the "A" and "B" SGTS were in compliance with TS, and a review of the operation logbook indicated that the TS-required monthly ! operation of the ESF systems was performed for the last 24 months. The inspectors
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found all control room indications and alarm systems to be operabl '
The inspectors also reviewed the licensee's evaluation concerning a testing problem for one train of the SGTS,' which exceeded the 720-hour total run time requirement for i testing. The staff identified the problem prior to exceeding the 25 percent grace period (allowed by TS), and the SGTS operation was switched to the alternate trai :
Therefore, no violations of TS had occurred. During the review, the licensee found that ;
the SGTS air handling system was sometimes used during drywell work or outage periods to provide adequate drywell ventilation. Routinely, the operations staff ,
, alternated the units to ensure that the 720-hour requirement was not exceeded. In this t l~ case, the licensee identified a failure of the staff to properly track and communicate the J l total run time. Following the incident, the staff implemented corrective actions to limit ,
j the likelihood of this in the future, t
On May 24,1998, during a routine visualinspection and as part of regular testing of the i SGTS, the staff located a 20-inch long pipe wrench below the charcoal beds inside one ;
of the SGTS trains. The wrench was removed; the licensee verified that the wrench did :
hts damage the charcoal beds; and the staff documented the finding in the test record !
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However, the staff did not enter the incident in the licensee's corrective actions program
. (i.e., action request (AR) system). The inspectors reviewed the issue and concluded that the presence of the pipe wrench did not have the potential for limiting operability of 3
, the SGTS. Although the technical staff indicated that this type of finding would normally l l
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result in the initiation of an AR, a communications problem between the engineering and l maintenance staff resulted in the omissio !
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Overall, the maintenance and testing program for the SGTS and SFU were effectively implemented. The licensee performed system testing in accordance with TS requirements, and test results indicated acceptable system performance. The licensee also identified and promptly resolved maintenance and operability issue R2,3 Process and Effluent Radiation Monitorina Instrumentation Inspection Scooe (IP 84750)
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The inspectors reviewed the operability and t.: ting of the process and effluent radiation
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calibration records and procedures, discussions with the responsible system engineer,
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l and a review of operability trends. Specifically, the inspectors reviewed calibration data for the following radiation monitors:
o Control room intake monitor; o- Offgas pre-treatment monitor; o Low Level Radwaste Processing and Storage Facility ventilation monitor; o Reactor Building exhaust vent monitors (Shafts 1,2, and 3);
o Turbine Building exhaust vent monitor; o Offgas stack monitor; .
o Residual heat removal system (RHR) service water monitor; and ,
o General service water monito '
, Observations and Findinas The inspectors performed a walk-down of the process and effluent radiation monitors with the responsible system engineer and members of the RP and chemistry staffs. The radiation monitors were in acceptable condition; however, the system engineer discussed challenges in maintaining the gaseous monitors. The inspectors noted that the system engineer had developed an effective tracking mechanism to identify the failure modes of these monitors and the frequency of each failure mode. Based on this tool and management support, the staff had achieved progress in eliminating some of the failure modes which were of the highest frequency. For example, the licensee had installed new flow controllers, which had corrected a problem with the older units. The system engineer also indicated that additional evaluations were in progress to evaluate the following: (1) " sticking" check sources; (2) replacement of data recorders; and (3)
installation of surge protectors. Based on the licensee's progress and on planned evolutions, the inspectors concluded that acceptable attention wac given to correcting the issues with these monitor The inspectors also reviewed selected calibrations of process and effluent radiation monitors and found the calibrations to be properly performed. The licensee had
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performed a primary calibration for each monitor to establish an energy dependence calibration and an activity calibration. ' At a prescribed frequency, the licensee also performed secondary calibrations to verify the adequacy of the continued use of the primary calibration. In the secondary calibrations, the licensee measured the response of the radiation monitor to a single radioactive source, which was related to the primary calibration. If the monitor did not respond within the licensee's acceptance criteria, the licensee performed corrective actions (e.g., adjusted the monitor's high voltage supply or replaced the monitor). To ensure the monitor responded properly to the anticipated mixture of radionuclides, the licensee compared the monitor's response to the analytical capabilities of the radiochemistry laboratory. Specifically, the staff injected a sample of gaseous radionuclides (i.e., untreated offgas) into the isolated radiation monitor and compared the radiation monitor's response to the analytical results obtained via the licensee's high purity germanium (HPGe) spectrophotometer, which was periodically l- calibrated with National Institute Science and Technology (NIST) traceable sources. If the monitor's response was not within 15 percent of the value obtained via the HPGe
spectrophotometer, the licensee performed additional analyses to evaluate any l statistical deviations and to determine if the conversion factor needed to be recalculated.
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The conversion factor was a calculated value which related the detectors response to l
the release rate of the radioactive gases (i.e., microcuries per cubic centimeters). i The inspectors reviewed selected 18-month channel calibrations and quarterly channel functional tests for the above monitors, which were performed as required by the TS and l ODAM. The inspectors verified certain alarm setpoints, which were calculated in accordance with the ODAM. The inspectors also noted that the licensee used the monitor indications to determine the quantity of radioactive noble gases which were released from the site. During the review of the calibration records, the inspectors noted that the "as found" values for certain monitors were not within the above acceptance i criteria for both of the parameters. In certain cases, the licensee adjusted the detector or calculated a new conversion factor, which was consistent with the applicable instructions. For example, the final conversion factors for the Rector Building vent j monitors (shafts 2 and 3) were about 50 percent less than the % found" value However, the RP staff indicated that they had not performed an evaluation to determine
, why the conversion factors had notably decreased or to determine t!0 effect of the changes on previously calculated effluent release data, which had been obtained from the monitors' responses. In addition, the inspectors questioned the acceptability of calibrating the monitors with 6.* untreated offgas sample. Although the chemistry technicians allowed the sampu to decay for about 20 to 30 minutes, the RP staff was not certain if the sample was acceptably representative of the mixture expected at the final effluent monitors. As indicated in Section R1.4, the offsite doses from routine effluent releases were only a small fraction of the regulatory limits. Consequently, the inspectors concluded that the fluctuations in monitor indication (observed during the above calibrations) would not have precluded the licensee from controlling the release of radioactive effluents in accordance with regulatory limits. However, the RP staff planned to evaluate the calibration practices and results and to make any necessary change Conclusions The licensee properly maintained effluent and process radiation monitors. For example, the system engineer trended system performance and identified the high frequency failure modes, which were being corrected. In addition, the staff had performed radiation monitor calibrations, as required by the licensee's TS and ODA The inspectors observed some problems concerning the stability of the radiation monitors. During routine calibrations of final effluent radiation monitors, the inspectors noted that the "as found" monitor indications were notably outside of the licensee's acceptance criteria. However, the staff did not evaluate this performance to determine the effect on annual effluent calculations or to determine the reason for the variance R4 Staff Knowledge and Performance in RP&C R4.1 Replacement of Effluent Monitor Filters (IP 84750)
The inspectors observed a chemistry technician replacing charcoal and particulate filters on the Reactor Building vent monitors. The technician demonstrated a good knowledge
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of the monitors and proper analytical techniques while removing and replacing the filters. The technician also questioned an anomaly in one of the timer indications, which demonstrated a questioning attitude. The inspectors noted that the technician performed the evolution in accordance with procedural requirements. During the evolution, the technician communicated with the operations staff to ensure that the
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control room staff was aware of the technician's activities and could anticipate abnormal monitor indications, which were expected. The inspectors observed these activities and did not identify any problem .
R4.2 Shioment of Radioactive Material (IP 86750)
During the inspection, the licensee conducted a shipment of radioactive material (Shipment No. 98-0062, Dry Active Waste). The inspectors observed the licensee prepare the shipment for transport and observed effective control of the vehicle and proper implements. tion of the shipping requirements. Specifically, the inspectors performed independent surveys of the shipping containers and the cas.-ier's vehicle and reviewed the shipping documentation. The inspectors' measurements were in good agreement with the licensee's survey results. In addition, the shipping documents contained the information required by 49 CFR Part 17 R7 Quality Assurance in RP&C Activities (IP 84750)
i The inspectors reviewed the quality assurance reviews of the chemistry and radioactive !
effluent programs which were performed in 1997 and 1998. The inspectors found the reports to be comprehensive. For example, the audit of the radioactive effluents program included a review of ODAP. changes, process radiation monitor operability challenges, and program implemontation. In addition, the auditor indicated that the ongoing review was concentrating on additional implementation areas. Overall, the audit findings indicated acceptable program performance. The inspectors also verified that the licensee had taken action to correct findings identifie R8 ' Miscellaneous RP&C lasues (IP 92904)
R (Closed) Insoection Follow-uo item (IFI) No. 50-331/97013-04: Since the heat-tracing associated with the hydrogen / oxygen monitor was not consistent with the design basis, the licensee planned to evaluate if the system would be able to obtain a representative 3 sample at the current temperature rating. During a subsequent NRC inspection (NRC l Inspection Report No. 50-331/98004(DRP)), the inspectors concluded that the monitor l was not operable and a Notice of Violation was issued for past inoperabilt !
Subsequently, the licensee corrected the problem with the heat-tracing. This item is j close R8.2 (Ooen) IFl No. 50-331/98017-01: The licensee planned to evaluate the training of RP technicians and revise the program (as applicable) to document training which was provided to the technicians to comply with Subpart H of 49 CFR Part 172. Prior to this inspection, the licensee had developed internal commitments to revise certain aspects of the RP technician training program and to include the above training in the site's training matrix and tracking system. The licensee planned to complete these actions in
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February of 1999. Consequently, the completion of these actiu 7 will be reviewed in subsequent NRC RP&C inspection V. Manaaement Meetinas X1 Exit Meeting Summary On December 4,1998, the in?,".ectors presented the inspection results to licensee management. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified which related to inspection findings.
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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Allison, Radwaste Shipping Coordinator R. Brown, Quality Assurance D. Carnesi, System Engineer D. Eilers, Radwaste and Material Handling Supervisor
- J. Franz, Vice President - Nuclear S. Funk, Health Physicist R. Hite, Radiation Protection Manager .
J. Karrick, Licensing -
L.- Kriege, Chemistry Supervisor D. Miller, Health Physics R. Murret, Licensing
'J. Newman, Radiological Engineering Supervisor R. Perry, Health Physics Supervisor K. Peveler, Regulatory Performance Manager K. Putnam, Licensing Manager B. Richmond, Health Physics D. Schebler, Quality Assurance T. Sims, System Engineer G. Van Middlesworth, Plant Manager T. Vine, Radwaste Supervisor D. Wilson, Assistant Vice President INSPECTION PROCEDURES USED IP 83750: : Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92904: Follow-up Plant Support
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ITEMS OPENED, CLOSED, AND DISCUSSED Opengs Non Qlosed
- 50-331/97013-04 IFl Hydrogen / oxygen monitoring in post accident conditions (Section R8.1).
Discussed 50-331/98017-01 IFl Radioactive shipping training for RP technicians (Section R8.2).
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LIST OF ACRONYMS USED . i ALAR . As-Low-As-is-Reasonably Achievable ALI Annual Limit on intake AR Action Request CEDE Committed Effective Dose Equivalent CFR- ' Code of Federal Regulations .
DAC - Derived Air Calculation l
.DR Division of Reactor Safety
ED Electronic Dosimeter ESF, Engineered Safety Feature HPG High Purity Germanium j HPP Health Physics Procedure IFl Inspection Follow-up item IP: Inspection Procedure ICRP . international Commission on Radiological Protection'
ISI . In Service inspection .
NIST National Institute of Science and Technology ,
NRC Nuclear Regulatory Commission . I NVLAP: National Voluntary Laboratory Accreditation Program ODAM Offsite Dose Assessment Manual PCM Portal Contamination Monito RCA Radiologically Controlled Area-
'RHR- Residual Heat Removal RP Radiation Protection RP&C Radiological Protection and Chemistry RPM Radiation Protection Manager SFU- Standby Filter Unit SGTS Standby Gas Treatment System
- TEDE Total Effective Dose Equivalent TLD Thermoluminescence Dosimeter TS Technical Specification VIO Violation L
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, . DOCUMENTS REVIEWED L ' Action Request (AR) No. 982962.'0 l l
!: Engineering / Maintenance / Radiation' Protection / Chemistry Assessment Team, Second Quarter '
Report.
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. Maintenance / Radiation Protection / Chemistry Assessment Team, Third Quarter Repor l
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Memorandum from David Miller to Jon Newman, " Dosimetry Report for the Third Quarter,1997," !
[ dated November 10,1997.'
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Memorandum from David Miller to Jon Newman, " Dosimetry Report for the Fourth Quarter,1997," dated March 3,1998.
! Memorandum from David Miller to Jon Newman, " Dosimetry Report for the First Quarter,1998," .
dated May 29,199 ,
Memorandum from David Miller to Jon Newman, " Dosimetry Report for the Second Quarter, 1998," dated September 1,199 Memorandum from David Miller to Jon Newman, " Dosimetry Report for the Third Quarter,1998,"
- dated November 6,199 i
- Procedures
- l ACP-1411.17 (Revision 8), " Occupational Dose Limits and Upgrades "
ACP-1411.18 (Revision 11), " Personnel Dosimetry,
! HPP-3102.20 (Revision 4), "ALARA Job Planning;" .
l HPP-3104.03 (Ravision 3)," Radiological Air Sample Collection and Analysis;"
HPP-3104.08 (Revision 6), " Shift Routine Air Samples;"
HPP-3105.05 (Revision 4), " Administration of in vivo and in vitro Bioassays;"
g HPP-3109.71 (Revision 5), " Operation of Whole Body Counting Systems" HPP-3109.82 (Revision 0), " Operation of SCBA Cylinder Charging System;" 1
- HPP-3109,84 (Revision 6), " Operation of TSI Model 8020 PortaCount "plus";"
l L HPP-3110.41 (Revision 2), " Calibration of Radeco Low Volume Air Samplers;" '
HPP-3110.42 (Revision 0), " Calibration of Eberline ERAS-1/ RAP-1 Low Volume Air Samplers;"
HPP-3110.43 (Revision 2), " Calibration of High Volume Air Samplers;"
HPP-3110.48 (Revision 6), " Calibration of Gilian Gil-Air (lapel) Air Samplers;"
r HPP-3110.71 (Revision 3), " Certification / Calibration of Whole Body Counting Systems;" HPP-3109.31 (Revision 4), " Operation of Eberline PCM-1B Personnel Monitors;" !
STP-3.6.4.3-01 (Revision 0), " Standby Gas Treatment and Standby Filer Unit
! Operation With Heaters On;"
l STP-3.6.4.3-02 (Revision 0), " Standby Gas Treatment System Heater Output Check;"
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STP-47 LOO 2-A (Revision 1), " Standby Gas Treatment System Heater' Output Check;"
STP-47 LOO 3 (Revision 5), " Standby Gas Treatment System HEPA'and Charcoal Filter Efficiency Tests;"
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STP-410A002 (Revision 6). " Main Control Room Ventilation Standby Filter Unit Test;" >
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STP-410B002 (Revision 6), " Main Control Room Ventilation Standby Filter Unit Test;" and -
STP-NS790601 (Revision 0), " Effluent P & 1 Sampling & Analysis."
Radiation Monitor Channel Calibrations:
STP 42D003-Q,CY, performed April 18,1997, through August 22,1997; STP 42D007-Q,CY, performed July 8,1997;
' STP NS79102-CY, performed February 10,1998; STP NS79104-CY, peformed May 27,1998;.
i STP NS79106-CY, performed January 9,1998;
. STP NS79108-CY, performed January 27,1998; STP NS79503-Q,Cy, performed November 4,1997; STP NS791002, performed September 30,1998; STP NS791013, performed October 8,1998; and STP NS790305, performed October 22,199 Radiation Protection & Chemistry Team, Second Quarter Report (1997).
RFO 14 Internal Dose Assessment RFO 15 Internal Dose Assessment T 20 .- --. , , - - , _ . . . .