IR 05000331/1999008

Insp Rept 50-331/99-08 on 990712-16 & 0810-12.No Violations Noted.Major Areas Inspected:Radiation Protection & Chemistry Programs

ML20211M574
Person / Time
Site:	Duane Arnold
Issue date:	09/02/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211M566	List: IR 05000331/1999008 ML20211M562
References
50-331-99-08, NUDOCS 9909090146
Download: ML20211M574 (12)

Text

_ _ _ - - - - _ .

'

'*

.

U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No: 50-331 License No: DPR-49 Report No: 50-331/99008(DRS)

Licensee: Alliant, IES Utilities In Facility: Duane Arnold Energy Center Location: Palo, Iowa Dates: July 12-16,1999 and August 10-12,1999 inspectors: K. Lambert, Radiation Specialist D. Nelson, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety

~

9909090146 990902 PDR ADOCK 05000331 G pm

'

.

.

EXECUTIVE SUMMARY Duane Arnold Nuclear Plant NRC Inspection Report 50-331/99008(DRS)

This routine inspection of the radiation protection and chemistry programs included a review of source term reduction and integration of the as-low-as-is-reasonably-achievable (ALARA)

program into work planning and execution; calibration, maintenance and operability of area radiation monitors and portable radiation survey instruments; quality assurance audits and self assessments of the radiation protection program; and a radioactive waste shipmen *

The ALARA planning and radiation work permit programs were effectively implemente The health physics staff was actively involved in the work planning process to ensure that radiation protection goals and concerns were addressed. (Section R1.1)

The station was effectively implementing source term reduction initiatives, and planning and coordinating work to reduce overall station dose. (Section R1.2)

The area radiation monitor calibration and maintenance program was adequately implemented. Personnel were knowledgeable regarding the instrumentation and calibration procedures. (Section R1.3)

-

The justification for not calibrating those radiation monitors not required for emergency operating procedures, regulatory guide 1.97, or criticality, was not weil documente (Section R1.3)

The licensee's portable radiation detection instrument calibration program was effectively implemented. Instruments were calibrated in accordance with station procedures and at the required frequency. (Section R1.4)

• The radiological posting and control of facilities and equipment were effectiv Radiological housekeeping was very good. Labeling of containers was effectiv (Section R2.1)

-

The audit plan was detailed and ensured that critical areas of the radiation protection program were reviewed during each operating cycle. The audits and assessments were of sufficient scope and depth to identify deficiencies and areas where improvements were warranted. Corrective actions to identify deficiencies were being effectively developed and implemented by the radiation protection staff. (Section R7.1)

-

The August 11,1999, transfer of the spent resin high integrity container from the resin storage vault to the shipping cask was well planned and executed. The August 11, I 1999, shipment of spent resin was in full compliance with NRC and DOT regulation I (Section R8.1) l l

,

>

,

.

.

.

.

Report Details IV. Plant Suncort R1 Radiological Protection and Chemistry Controls R1.1 As-Low-As-Is-Reasonablv-Achievable (ALARA) Imolementation inspection Scope (8375Q)

The inspectors reviewed the station's program for performing ALARA reviews, the development of radiation work permits (RWP), and the integration of the ALARA program into work planning. The review included applicable procedures, ALARA plans, RWPs and discussions with cognizant personne Observations and Findinas The inspectors' review of station procedures indicated that the procedures were sufficiently detailed and were consistent with industry guidance. A member of the health physics staff was assigned to work planning full time. This ensured that the health physics staff was aware of upcoming work, and that the ALARA staff had early input into the planning process for those jobs with the potential for higher doses or contaminatio In addition, another member of the health physics staff was assigned to the B2R08 outage planning group full tim Health Physics staff attended planning meetings held 6 weeks,3 weeks, and 1 week ahead of scheduled activities. During the six-week look ahead planning meeting, radiological concems were discussed and Form HP-55 Checklist was completed. Form HP-55 Checklist assists in determining whether a formal ALARA review was needed or if an RWP would be acceptable. The health physics technician assigned to develop the RWP or the ALARA review would be the technician providing health physics support during the activity. For those jobs requiring an ALARA review, a job tracking folder was developed that included previous work history, industry events, lessons learned from previous evolutions, and meeting minutes. ALARA post task summaries were performed for those jobs requiring an ALARA revie The inspectors reviewed several RWPs and ALARA plans, and ALARA post task summaries. ALARA plans were detailed and incorporated lessons learned from previous job evolutions. The job tracking folder, which contained the ALARA plan, was kept with the RWP. RWPs were appropriately completed and provided applicable radiation protection information including survey information, hold points, protec+ive clothing requirements, and special instruction Conclusions The ALARA planning and RWP programs were effectively implemented. The health physics staff was actively involved in the work planning process to ensure that radiation protection goals and concerns were addresse I

.

.

_

.

R1.2 Source Term Reduction Inspection Scope (83750)

The inspectors discussed source term reduction efforts with cognizant members of the health physics staff, Observations and Findinas Source term reduction efforts included removal of stellite bearing control rod blade pins and rollers (1993), a high stellite valve removal program (since 1994), depleted zinc injection (since 1994), and noble metalinjection (1996). Current source term reduction efforts included a hot spot tracking system, permanent shielding, and flushing of component systems. The station was tracking approximately 12 hot spots and included information on when the spot was last flushed and current dose rates to assist in determining when additional flushing would be needed. The station also has planned to perform hydrotazing of the residual heat removal system during future valve maintenance activities. In addition to source term reduction, other activities to reduce dose included weld inspection relief, increased usage of remote cameras, and the use of wet lift equipment during the last refueling outage. The wet lift equipment allowed reactor lifts without personnel entering the cavity for rigging purpose As the result of source term reduction and other dose reduction activities, the station dose had been steadily declining. The total station dose for 1998 was 237 person-rem as compared with the 1996 station dose of 270 person-rem (includes outage doses).

Non outage doses for 1996,1997, and 1998 were 79 person-rem,63 person-rem, and 50 person-re Conclusions

'

The station was effectively implementing source term reduction initiatives, and planning and coordinating work to reduce overall station dos R1.3 Area Radiation Monitor Calibration and Operability Inspection Scope (84750)

The inspectors reviewed the calibration and operability of the area radiation monitors (ARMS). The review included selected calibration and maintenance records, in-field observations, interviews with applicable personnel, and the applicable requirements in the Updated Final Safety Analysis Report (UFSAR) and Technical Specification Observations and Findinas The ARMS monitor plant radiation levels and provide notification of abnormal gamma radiation levels in areas where radioactive materials may be used, stored, or handled, and to provide indications of radiation levels in specific areas of the plant. The Instrumentation and Control (l&C) group performs the calibration and routine

_ . . . .. _

.

maintenance of the monitors. Readouts were provided in the control room for the ARMS, with selected monitors providing local readout The inspectors reviewed calibration data for 1997,1998, and 1999. Calibrations were performed at the required frequencies and calibrations were appropriately documented on calibration forms. The calibration frequency was changed from every year to every two years in February 1999, based on good operability and during calibrations as found readings were within the acceptance criteria. The licensee documented their justification for changing the calibration frequency. The system engineer indicated that he and I&C personnel review the monitors for operability when calibrations were performed and in response to any monitor failures. The system engineer also indicated that monitor failures were rare and generally the result of a degraded detector. The system engineer and cognizant l&C personnel were knowledgeable regarding the area radiation monitoring system and applicable calibration and maintenance procedure During plant walk downs, the inspectors observed ARMS in good operating conditio For selected monitors, the inspectors verified that the location, and remote (control room) and local (if applicable) indications were as described in the UFSAR in April 1999, the licensee determined that ARMS, not associated with emergency operating procedures, criticality, or regulatory guide 1.97 (Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident) were no longer to be calibrated. The licensee indicated their justification was that the data was not used. When the monitors alarmed, either low or high alarm, the monitor would be evaluated and if the alarm were not due to actual radiation conditions, the monitor would then be repaired and calibrated. The licensee documented their justification on "PMAR Input Request Form," 99-0307, which indicated that the monitors did not meet the requirements for performing maintenance activities in Section 3.1," Guidelines for Implementing Preventive Maintenance," of procedure ACP 1208.3, revision 3," Preventive Maintenance Program." The inspectors, discussed with station personnel, that the monitors were referenced in the UFSAR, and that there was a lack of documentation regarding the licensee's justification for not calibrating the referenced monitors. Station management agreed that additional documentation may be warranted, and initiated Action Request (AR) 16454 to evaluate whether the UFSAR required updating, and whether there was sufficient documentation to determine that calibrations were not required. The licensee's review and response to AR 16454 will be reviewed in subsequent radiation protection inspections (IFl 50-331/99008-01(DRS)).

c. Conclusions The area radiation monitor calibration and maintenance program was adequately implemented. Personnel were knowledgeable regarding the instrumentation and I calibration procedures. However, the justification for not calibrating those radiation monitors not required for emergency operating procedures, regulatory guide 1.97, or criticality, was not well documente I

-

.,

R1.4 Portable Radiation Detection Instrument Calibrations Insoection Scoce (83750)

The inspectors reviewed the calibration procedures and records for the station's portable radiation detection instruments concentrating on the Eberline RO-2, RO-2A and RO-20 lonization chamber Observations and Findir$as The inspectors verified that the licensee calibrated the portable radiation detection instruments in accordance with the procedural requirements. Calibration records indicated that the RO-2, RO-2A and RO-20 instruments had been calibrated at 20 and 80 percent of each linear range, each instrument had been beta source checked and all ;

instruments that failed the +/-10% acceptance criteria had been recalibrated or set aside l for repai )

The inspectors also verified that those instruments that were due for calibration were f

removed from service. The licensee generated monthly, quarterly, semi annual and j annualinventory sheets. The sheets contained the instrument name, serial number of I each instrument owned by the licensee, the instrument's location, calibration due date, and whether it was in or out of service. The individual responsible for maintaining the inventories was also responsible for generating the weekly " Pull at Access" report. The )

" Pull at Access" report directs the duty radiation protection technician to locate the instruments in the report and transfer each instrument to the calibration laboratory for calibration. Those instruments removed from service for calibration or that cannot be found were to be marked in the inventory as out of service. The instruments removed from service were also affixed with an "out of service" tag. The inspector noted that all instruments that had a calibration due date of August 1999 had been marked on the inventory sheets as "out of service" and the instruments were tagge Conclusions l

The licensee's portable radiation detection instrument calibration program was i effectively implemented. Instruments were calibrated in accordance with station '

procedures and at the required frequenc R2 Status of Radiation Protection and Chemistry Facilities and Equipment R Radioloalcal Postina and Labelina of Facilities and Eauioment Inspection Scope (83750)

The inspectors reviewed the radiological postings and labeling of containers in the Reactor, Turbine, and Low-Level Radwaste Processing and Storage Buildings. In addition, material condition of radiological equipment and housekeeping practices were reviewe .

. Observations The inspectors observed during the tours that high radiation areas, locked high radiation areas and contamination areas were properly posted and controlled. Radiological housekeeping in all of the buildings was generally very good and all waste containers were clearly marked with the proper labels. All other containers including drums, cabinets, tool boxes, and gang boxes housing potentially contaminated materials, tools or equipment were labeled as " radioactive materials." Conclusions The radiological posting and control of facilities and equipment were effectiv Radiological housekeeping was very good. Labeling of containers was effectiv R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Radiation Protection Quality Assurance Assessments Insoection Scoce (83750)

The inspectors reviewed the licensee's quality assurance program related to the maintenance, radiation protection and chemistry programs. This included reviews of the quarterly assessment plans for 1998 and 1999, and the radiation protection staff's self assessments and job performance observations. This review also included discussions with cognizant radiation protection and nuclear oversight staff, Observations and Findinas The auditing program was implemented in accordance with station procedures that divided audits into functional assessment areas. The Maintenance / Radiation Protection /

Chemistry assessment area included 18 functional areas to be reviewed. These areas were reviewed over an operating cycle, typically two years. The procedure required that an audit of the assessment area be performed every quarter. The station had l developed an audit plan that ensured that all 18 functional areas were reviewed during the operating cycle and that audits were performed quarterly. The plan was also ,

flexible, such that additional areas could be included based on requests from radiation J protection or a review of the action request system, where negative performance trends may have been identified. In addition, radiation protection management performed quarterly self assessments, and monthly job observation The inspectors reviewed radiation protection program audits performed in 1998 and the .

first quarter of 1999, determining that the assessments were of sufficient depth to l identify deficiencies. Action requests were initiated for those areas with findings to track

-

radiation protection staff's corrective actions. The assessments concluded that the l radiation protection program was effectively implemented, with only a few minor j deficiencies identified that were being adequately addressed by radiation protection 1 staff. The assessments also reviewed results of corrective actions from previous audit l l

l i

l s

'

.

The inspectors also verified that the quarterly assessments for the current operating 1 cycle included all the functional areas required to be reviewe Conclusions The audit plan was detailed and ensured that critical areas of the radiation protection l program were reviewed during each operating cycle. The Audits and assessments were of sufficient scope and depth to identify deficiencies and areas where improvements were warranted. Corrective actions to identify deficiencies were being effectively developed and implemented by the radiation protection staf R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 Shioment of Radioactive Material (86750)

1 Inspection Scone The inspectors reviewed the shipping documents for the August 11,1999, shipment of spent condensate resin from the site to a licensed low-level waste disposal facility. The inspectors also attended the pre-job briefing for transferring the High Integrity Container 4 (HIC) housing the spent resin from the resin storage vault to the shipping cas i Observations and Findinas )

On August 11,1999, the licensee shipped approximately 200 cubic feet of spent condensate resin to a licensed low-level waste disposal facility (Shipment No. RSR 99- i 24). The inspectors interviewed the individual responsible for the shipment and reviewed the completed shipping documents immediately before the shipment left the site. The document review indicated that the proper pre-shipment state and burial site ;

'

notifications had been made; that the analyses of the spent resin had been performed in accordance with 10 CFR Part 61 and station procedures; and that the HIC, shipping cask and vehicle had been properly surveyed. In addition, the inspectors noted that the shipping documents contained all of the information required by the Department of Transportation in 49 CFR Part 17 The inspectors attended the pre-job briefing for the transfer of the HIC containing the spent resia from the resin storage vault to the shipping cask. The inspectors observed that the pre-job briefing was low key in tone and conversational in format. Perhaps because of the format, it was unclear to the inspectors who was leading the presentation and who was responsible for the project. The inspectors noted, however, that since many of the attendees had participated in a resin HIC transfer, the informal format did not appear to distract from the briefing. The attendees appeared to be attentive and l willing to actively participate in the briefing. Many questions were raised during the briefing and the answers appeared to satisfy those present. The inspectors discussed these observations with plant management, who indicated that pre-job briefings were being reviewed for possible revisions to content and forma o

.

.

During the transfer of the resin HIC to the shipping cask the inspectors observed that barriers with High Radiation Area postings had been erected at all of the entrances into the work site. Radiation protection technicians were observed at the work site restricting access and frequently checking the participants' electronic dosimeters. Although the dose rate on the surface of the HlC was approximately 1.5 R/ hour, total dose for the transfer was approximately 20 millirem, indicating good work planning and executio Conclusions The August 11,1999, transfer of the spent resin HIC from the resin storage vault to the shipping cask was well planned and executed. The August 11,1999, shipment of spent resin was in full compliance with NRC and DOT regulation R8.2 (Closed)Insoection Followuo item 50-133/98017-01: Radioactive shipping training for radiation protection technicians. The licensee evaluated the training of radiation ,

protection technicians and revised the program to document the training provided to the j technicians to comply with Subpart H of 49 CFR Part 172. In addition, the licensee ;

identified those tasks that were to be part of Subpart H training. Technician training was j completed in July 1999, for all individuals except one technician who has been assigned to provide radiation protection coverage on the refuel floor during new fuel receipt. The station planned to train this individual after new fuel receipt activities were complete This item is close X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on May 21,1999. The licensee acknowledged the findings presented. The licensee did not identify any information discussed as proprietar ,

l l

1

!

.,

.

PMtTIAL LIST OF PERSONS CONTACTED Licensee J. Ertman, Engineering Team Leader B. Harcek, Health Physics R. Hite, Radiation Protection Manager S. Ingram, System Engineer J. Karrick, Licensing -

B. Klotz, AR Administrator M. McDermott, Engineering Manager D. Miller, Health Physics, ALARA R. Perry, Health Physics Supervisor B. Richmond, Health Physics D. Schebler, Quality Assurance K. Schneider, Equipment Maintenance Team Leader G. Van Middlesworth, Plant Manager T. Vine, Radwaste Supervisor R. Wheaton, Instrument and Controls Team Leader 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 Followup - Plant Support LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened i

50-133/98017-01 IFl Justification documentation for not calibrating area radiation monitors referenced in the Updated Safety Analysis Report Closed 50-133/98017-01 IFl Radioactive shipping training for radiation protection technicians Discussed None

.

J

+

.,

e LIST OF ACRONYMS USED ALARA As-Low-As-Is-Reasonably-Achievable AR Action Request ARMS Area Radiation Monitors DRS Division of Reactor Safety HIC High Integrity Container IFl Inspection Followup Item NRC Nuclear Regulatory Commission PDR Public Document Room R/hr Roentgens per Hour RWP Radiation Work Permit UFSAR Updated Final Safety Analysis Report

.

-

o

.,

.

LIST OF DOCUMENTS REVIEWED Action Reo2eit AR 16138 Area rad monitor calibration documents not reviewed AR 16453 "PM Program ACP 1208.3" AR 16454 " Area Rad Monitor Calibrations Deleted Without UFSAR Update / Basis Documentation" Procedures Administrative Control Procedure, ACP 1208.3, Revision 3," Preventive Maintenance Program" Health Physics Procedure, HPP 3101.05, Revision 13, " Administration of Radiation Work Permits (RWPS)"

Health Physics Procedure, HPP 3102.02, Revision 6, "ALARA Job Planning" Health Physics Procedure HPP 3110.01, Revision 4," Calibration of Eberline RO-2, RO-2A, and RO-20" Health Physics Procedure, HPP 3110.02, Revision 3," Calibration of Eberline RO-7 lon Chamber" Health Physics Procedure, HPP 3110.03, Revision 3, * Calibration of Eberline Teletector Dose Rate Meter" Health Physics Procedure, HPP 3110.05, Revision 3, " Calibration of Eberline E-140 count Rate Meter" Health Physics Procedure, HPDI-003, Revision 2, " Job Observation and Surveillance / Inspection Program" Health Physics Procedure, HPDI-004, Revision 12," Health Physics Self Assessment Program" Maintenance Procedure, l. RIM-G080-01, Revision 12. " General Electric Area Radiation Monitors" Maintenance Procedure, l. RIM-V115-01, Revision 6, "Victoreen, Inc. Model 876A Containment Radiation Monitors" Maintenance Procedure, l. RIM-E070-01, Revision 2,"Ebertine Model RMS 11 Area Radiation Monitors" Quality Assurance Procedure, No.1116.4, Revision 11," Internal Assessment Program" Miscellaneous Area Radiation Monitor Calibration Data Sheets,1997,1998, and 1999 PMAR Input Request Form 99-0101 PMAR Input Request Form 99-0307 Health Physics Technician Training Matrix, printed 8/11/1999 Maintenance Job Assessment for Rad Worker improvement,9/25/1997 January 1998 Foreman Observation of Electrician Interface with HPs Monthly foreman Tour with l&C Maintenance QA Maintenance / Radiation Protection / Chemistry Assessment Team Plan for Cycle 16 Maintenance-Radiation Protection-Chemistry Quarterly Assessments for 1998 and 1999 Duane Amold Energy Center Radiation Protection Program and Performance Enhancements Station Dose Summary Data (1976 to 1998)

12