IR 05000313/2004009

IR 05000313-04-09, 05000368-04-09; Arkansas Nuclear One, Units 1 and 2; Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems; Radioactive Material Processing and Transportation; Radioactive Material Control Program

ML042370271
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/24/2004
From:	Shannon M Division of Reactor Safety IV
To:	Forbes J Entergy Operations
References
IR-04-009
Download: ML042370271 (25)

Text

August 24, 2004 Jeffrey S. Forbes, Site Vice President, Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72801-0967 SUBJECT: ARKANSAS NUCLEAR ONE - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000313/2004009 and 05000368/2004009 On June 18, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Units 1 and 2 facility. After additional information was reviewed, the team conducted a telephone conference on July 22, 2004. The enclosed integrated report documents the inspection findings, which were discussed at the conclusion of the inspection with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:

• Radiation Monitoring Instrumentation

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

• Radioactive Material Processing and Transportation

• Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one NRC-identified finding and one self-revealing finding of very low safety significance (Green). However, because of their very low safety significance and because the findings were entered into your corrective action program, the NRC is treating these findings as noncited violations (NCVs) consistent with Section V1.A of the NRC Enforcement Policy. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in Section 4OA7 of this report. If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Arkansas Nuclear One, Units 1 and 2, facilit Entergy Operations, In In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

//RA//

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-313 50-368 Licenses: DPR-51 NPF-6

Enclosure:

NRC Inspection Report 05000313/2004009 and 05000368/2004009 w/Attachment: Supplemental Information

REGION IV==

Dockets: 50-313, 50-368 Licenses: DPR-51, NPF-6 Report: 05000313/2004009 and 05000368/2004009 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64W and Hwy. 333 South Russellville, Arkansas Dates: June 14 through July 22, 2004 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch George Kuzo, Senior Health Physicist, NRC Region II Bernadette Baca, Health Physicist, Plant Support Branch Daniel R. Carter, Health Physicist, Plant Support Branch Approved By: Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000313/2004-09, 05000368/2004-09; Arkansas Nuclear One, Units 1 and 2; Radioactive

Gaseous and Liquid Effluent Treatment and Monitoring Systems; Radioactive Material Processing and Transportation; Radioactive Material Control Program The report covered a one week period of inspection on site by a team of four region-based health physics inspectors. Two findings of very low safety significance (Green) were identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process, (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Cornerstone: Public Radiation Safety

Green.

The team identified a non-cited violation of Unit 1 Technical Specification 5.5.4 because the licensee failed to calibrate selected effluent monitoring instrumentation in accordance with Offsite Dose Calculation Manual specifications. Specifically, the liquid radioactive waste monitor (RE-4642) and the waste gas holdup system monitor (RE-4830) were not calibrated across the full range of energies that the instruments would be expected to detect.

Additionally, the licensees calibration process for these monitors did not establish that the channel outputs responded with an acceptable range and accuracy to the primary or secondary calibration sources. The licensee used a radioactive source to qualitatively verify that the monitor identified the primary calibration source energy peak but did not require a quantitative response. The finding was placed into the licensees corrective action program.

The finding is more than minor because it was associated with the Public Radiation Safety Cornerstone plant equipment/process radiation monitoring attribute and affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding had very low safety significance because: (1) the finding did not involve radioactive material control, (2) it involved the effluent release program, (3) it impaired the licensees ability to assess dose, (4) it did not result in the licensees failure to assess dose because the licensee was able to assess dose by alternate means, and (5) doses did not exceed 10 CFR Part 50, Appendix I, values (Section 2PS1).

Green.

The team reviewed a self-revealing, non-cited violation of 10 CFR 71.47 resulting from the licensees failure to correctly prepare a radioactive shipment so that dose rates did not exceed regulatory limits. Specifically, on March 24, 2003, the licensee was notified by a shipment recipient that the contact radiation dose rate of a package exceeded 200 millirem per hour. A contact radiation dose rate of 380 millirem per hour was identified on the bottom of the package. However, the accessible radiation levels to the public from underneath the flatbed trailer were only 70 millirem per hour. The finding was placed into the licensees corrective action program.

The finding was greater than minor because it is associated with the Public Radiation Safety Cornerstone attribute of Program and Process and affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials). The finding involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC regulations, therefore it was evaluated using the Public Radiation Safety Significance Determination Process. The finding had very low safety significance because: (1) it involved radioactive material control, (2) it was a transportation issue, (3) external radiation levels were exceeded, (4) dose rates in excess of regulatory limits were not accessible to the public, and (5) the radiation levels did not exceed two times the federal limits. This finding also had crosscutting aspects associated with human performance (Section 2PS2).

B. Licensee Identified Violation A violation of very low safety significance (Green) which was identified by the licensee was reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number is listed in Section 4OA7.

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area

• Self-assessments and audits

• Corrective action program reports since the last inspection

• Calibration expiration and source response check currency on radiation detection instruments staged for use

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units The licensee uses the Entergy Operations, Inc. central calibration facility. Therefore, the following item could not be reviewed during this inspection.

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee Event Reports

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies The inspector completed 9 of the required 9 samples.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual (ODCM), and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, self-assessments, audits, and licensee event reports

• Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluents as well as radioactive liquid and gaseous effluent release permits and dose projections to members of the public

• Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection

• Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control

• Interlaboratory comparison program results

• Audits and self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Abnormal releases

• Licensee event reports and special reports The inspector completed 10 of the required 10 samples.

b. Findings

Introduction.

The team identified a Green, non-cited violation (NCV) because the licensee failed to implement ODCM calibration requirements for selected effluent process monitors.

Description.

During personnel interviews and record reviews related to the calibration of the Unit 1 Liquid Radioactive Waste Monitor (RE-4642) and the Waste Gas Holdup System Monitor (RE-4830), the team identified two calibration problems. First, the subject monitors were not calibrated across the full range of energies that the instruments would be expected to detect. The recent effluent report data confirmed the presence of multiple radionuclides having a wide range of energies in both the liquid and gaseous effluent pathways. However, the most recent primary in-situ calibration record for each of these monitors confirmed that the licensee used a single source (Cs-137 for the liquid monitor and Kr-85 for the gas monitor), rather than a mixture of isotopes encompassing the entire range of energies.

Second, the licensees calibration process for these two monitors did not establish that the channel outputs responded with acceptable range and accuracy to the (NIST-traceable)primary or secondary sources. Instead, the licensee used the radioactive source only to qualitatively verify that the monitor identified the primary calibration source energy peak.

The licensees Unit 1 calibration procedure did not require a quantitative response.

Therefore, no quantitative acceptance criteria were established for subsequent (secondary) calibrations. In contrast, the team noted that analogous calibration procedures for monitors in Unit 2 correctly included criteria for a quantitative response within the established ranges.

Analysis.

The team determined that the licensees failure to correctly calibrate the process effluent monitors was a performance deficiency because the licensee did not meet the ODCM requirements. The finding is more than minor because it was associated with the Public Radiation Safety Cornerstone plant equipment/process radiation monitoring attribute and affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding involved an occurrence in the licensees radiological effluent monitoring program that is contrary to requirements in the licensees ODCM; therefore, the team used the Public Radiation Safety Significance Determination Process.

The finding had very low safety significance because:

(1) the finding did not involve radioactive material control,

(2) it involved the effluent release program,

(3) it impaired the licensees ability to assess dose,

(4) it did not result in the licensees failure to assess dose because the licensee was able to assess dose by alternate means, and

(5) doses did not exceed 10 CFR Part 50,Appendix I, values.

Enforcement.

Technical Specification 5.5.4(a) establishes limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM. ODCM Appendix 1, Surveillance Limitation Requirements S2.1.1 and S2.2.1 require, respectively, that each radioactive liquid and gaseous effluent monitoring instrumentation channel be demonstrated operable by performance of the channel check, source check, channel calibration and analog channel operational test at the frequencies shown in Table 2.1-2 and Table 2.2-2. Table 2.1-2 and Table 2.2-2, respectively, require the monitor on the liquid effluent line and monitors on the gas decay tank systems be calibrated at least once per 18 months. Bases BL2.1.1 for Table 2.1-2, and BL 2.2.1 for Table 2.2-2, require initial channel calibrations be performed over their intended range of energy and measurements using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. For subsequent channel calibration, sources that have been related to the initial calibration shall be used. ODCM Appendix 1, Section 1.4, defines an instrument channel calibration as a test, and adjustment (if necessary), to establish that the channel output responds with acceptable range and accuracy to known values of the parameter which the channel measures or an accurate simulation of these values.

The licensee violated this requirement when it failed to establish that the channel outputs of Unit 1 liquid release monitor and the Unit 1 Waste Gas Decay System Effluent monitoring system respond with acceptable range and accuracy to known values of the energies and activities of radioactive effluents released from the licensees facility.

Because the failure to correctly calibrate effluent monitors was determined to be of very low safety significance and has been entered into the licensees corrective action program as Condition Reports CR-ANO-1-2004-01629 and CR-ANO-1-2004-01740, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy:

NCV 05000313/2004009-01, Failure to calibrate selected Unit 1 effluent monitoring instrumentation in accordance with ODCM requirements.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting

• Shipping records for non-excepted package shipments

• Audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

C Shipments of radioactive materials.

C Licensee event reports and special reports The inspector completed 6 of the required 6 samples.

b. Findings

Introduction.

The team reviewed a Green self-revealing, non-cited violation of 10 CFR 71.47. The licensee failed to prepare a shipment for transportation so that the radiation level did not exceed 200 millirem per hour at any point on the external surface of the package.

Description.

The team reviewed Condition Report CR-ANO-C-2003-00227. It documented that, on March 24, 2003, the licensee was notified by a shipment receiver that a radioactive package of control rod drive mechanisms had radiation levels on the package in excess of federal limits. Radiation levels of 380 millirem per hour were identified on contact with the bottom of the package. However, the accessible radiation levels to the public from underneath the flatbed trailer were only 70 millirem per hour.

The licensees exit survey indicated that the highest dose rate on the bottom of the trailer, prior to leaving the site, was 55 millirem per hour.

The licensee dispatched a representative to evaluate the package condition. On March 25, 2003, the representative confirmed the dose rate to be 360 millirem per hour using a licensee survey instrument. The representatives inspection of the package revealed that the control rod drive mechanisms cribbing and lead shielding had moved during transit. This caused the radioactive components to be unshielded or less effectively shielded, resulting in increased dose rates.

Analysis.

The failure to prepare a shipment to comply with federal regulations is a performance deficiency. The finding was greater than minor because it is associated with the Public Radiation Safety Cornerstone attribute of Program and Process and affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials). The finding involved an occurrence in the licensees radioactive material transportation program that is contrary to NRC regulations, therefore it was evaluated using the Public Radiation Safety Significance Determination Process. The finding had very low safety significance because:

(1) it involved radioactive material control,

(2) it was a transportation issue,

(3) external radiation levels were exceeded,

(4) dose rates in excess of regulatory limits were not accessible to the public, and

(5) the radiation levels did not exceed two times the federal limits. This finding had crosscutting aspects associated with human performance. The failure of licensee personnel to follow programmatic guidance for shipment preparation directly contributed to the finding.

Enforcement.

10 CFR 71.47 states in part, that each package of radioactive materials offered for transportation must be designed and prepared for shipment so that, under conditions normally incident to transportation, the radiation level does not exceed 200 millirem per hour at any point on the external surface of the package.

The licensee violated this requirement when it failed to prepare the package so that it did not exceed federal limits. Because this failure is of very low safety significance and has been entered into the licensees corrective action system as condition report CR-ANO-C-2003-00227, this violation is being treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000313/200409-02; 05000368/200409-02, Radioactive Shipment Package Exceeded 10 CFR 71.47 Radiation Limits.

2PS3 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program (71122.03)

a. Inspection Scope

This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I, the ODCM, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed

• Annual environmental monitoring reports

• A sampling of air sampling stations and thermoluminescence dosimeter (TLD)monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement

• Calibration and maintenance records for air samplers and environmental sample radiation measurement instrumentation, quality control program, and interlaboratory comparison program results

• Locations where the licensee monitors potentially contaminated material leaving the controlled access area and the methods used for control, survey, and release from these areas

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records

• Audits, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection

• Licensee event reports and special reports performed since the last inspection The inspector completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

Annual Sample Review

a. Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation Monitoring Instrumentation (Section 2OS3)

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)

• Radioactive Material Processing and Transportation (Section 2PS2)

• Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)

b. Findings and Observations

No findings of significance were identified.

4OA4 Cross-Cutting Aspects of Findings

Section 2PS2 describes an issue with a human performance cross-cutting aspect which involved the failure of workers to correctly prepare a radioactive shipment for transportation.

4OA6 Management Meetings

Exit Meeting Summary

On June 18, 2004, the team presented the inspection results to Mr. J. Forbes, Site Vice President, and other members of his staff who acknowledged the findings, but stated that they would provide additional information related to effluent monitor calibrations. The team confirmed that proprietary information was not provided or examined during the inspection. After the additional information was reviewed, the team conducted a telephone conference on July 22, 2004, and discussed the results with Messrs. D. James, Manager, Licensing, and R. Scheide, Specialist, Licensing.

4OA7 Licensee-Identified Violations

The following finding of very low safety significance was identified by the licensee as a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a NCV.

Unit 2 Technical Specification 6.8.1.a requires written procedures applicable to Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 7, references procedures for control of radioactivity. Procedure 1012.020, Radioactive Material Control, Change Number 006-05-0, Section 6.9.1 states, in part, that any item which has been evaluated to have no inaccessible areas that may have become contaminated and has no detectable contamination greater than the minimum sensitivity of the combined survey method and instrument may be unconditionally released from radiological restrictions. However, on September 24, 2003, a vacuum cleaner containing radioactive material was found in an un-posted area of the Unit 2 Turbine Building, outside the controlled access area. This issue is documented in the licensees corrective action program by Condition Report CR-ANO-2-2003-01302. Using the Public Radiation Safety Significance Determination Process, the team determined that the finding is of very low safety significance because

(1) the finding was a radioactive material control issue

(2) it was not a transportation issue,

(3) it did not result in a dose to the public greater than 0.005 rem, and

(4) the number of occurrences was not greater than five.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Briggs, Specialist, Instruments and Controls

W. Burke, Supervisor, Chemistry

D. Calloway, Specialist, Chemistry

G. Damron, Technician, Radiation Protection

D. Hawkins, Specialist, Licensing

D. Hicks, Radwaste Supervisor, Radiation Protection

D. James, Manager, Licensing

M. McCullah, Transportation Specialist, Radiation Protection

D. Moore, Supervisor, Radiation Protection

S. Morris, Specialist III, Health Physics/Chemistry

B. Patrick, Manager, Radiation Protection

T. Rolniak, Supervisor, Radiation Protection

R. Sheide, Specialist, Licensing

G. Stephenson, Senior Specialist, Health Physics/Chemistry

D. White, Specialist, Chemistry

NRC

R. Deese, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Opened and Closed During this Inspection

05000313/2004009-01 NCV Failure to Calibrate Select Unit 1 Effluent Process Monitors In Accordance with ODCM Requirements (Section 2PS1)

05000313,368/2004009-02 NCV Radioactive Shipment Package Exceeded 10 CFR 71.47 Radiation Limits.

Previous Items

Closed

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