IR 05000458/1989044
| ML20012C100 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/16/1990 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012C099 | List: |
| References | |
| 50-458-89-44, NUDOCS 9003200091 | |
| Download: ML20012C100 (13) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
NRC Inspection' Report:
50-458/89-44 Operating License: NPF-47 Docket:- 50-458 Licensee: Gulf States Utilities (GSU)
P.O. Box 220 St. Francisv111e, Louisiana 70775
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. Facility Name:
River Bend Station (RBS)
Inspection At:
RBS Site, St. Francisville, Louisiana l
Inspection Conducted:= December 18-22, 1989 o
>r A
M(aMD Inspector:
v R? E. BaFr, Sr.' Reactor Health Physicist,
.Da'te Facilities Radiological Protection Section
' Accompanied
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B.~Murray,jO h ]] & %*1 Ylb/TO
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.by:
,ChiefTFacil es Padiological Date
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Protection: Section (
ember 19 & 20, 1989)
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Approved:
A.#
NL kk B.Murray, Chief,FacilipsRadiological Date
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Protection-Section
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Inspection Summary Inspection' Conducted December 18-22, 1989 (Report 50-458/89-44)
Areas-Inspected:
Routine, unannounced inspection of licensee _'s occupational radiation protection program including: audits and appraisals, changes, training and qualifications, external exposure controls, internal exposure controls,-control of radioactive material and contamination, and the ALARA-program.
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.Results: -The licensee had maintained an effective radiation protection program. Management provided support to the program. Audits are comprehensive
,and designed to verify compliance with plant procedures, but are not directed itoward identification of procedure or program weaknesses.
Several initiatives-have been implemented by the ALARA group to= reduce person-rem values from existing radiation levels.
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-2-High radiation levels are present in the drywell due to cobalt-60 and the licensee has established a Task Force to investigate the source of the
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cobalt-60. A formal training program has not been established for radiation protection supervisors and professionals.
It was observed that the licensee utilizes the minimum number of constant air monitors as called for in the Updated Safety Analysis Report (USAR), and this minimum coverage may cause some piant. areas not to have immediate warning to personnel in the event of an airborne release.
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_3 DETAILS 1.
Persons Contacted
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- T. F. Plunkett, Plant Manager
- D. L. Andrews, Director, Nuclear Training
- R, Backen, Supervisor, Quality Systems W, T. Bullard, Senior Health Physicist
- J. W. Cook, Licensing Technical Assistant
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- C, L. Fantacci, _ Radiological Engineering Supervisor
- D. N. Fauver, Radiological Health Supervi.sor
- R. W. Frater, Director, Projects P, Graham, Technical Advisor-to Senior Vice President
- W. -C. Hardy, Radiation Protection Supervisor
- G. R. Kimmell, Director, Quality Services l
- J. C. Maher, Licensing Engineer I, M. Malik, Operations Quality Assurance (QA) Supervisor
S. F. Moulard, Electrical Maintenance-Foreman
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B.-R, Smith, Mechanical-Planning
'l J. E. Spivey, Senior QA Engineer
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S. K. Stoma, Operations QA Engineer V. T. Trude11, Operations Shift Supervisor
- R. J. Vachon, Senior Compliance Analyst G. D, Valentine, Nuclear Training Representative
- M. A. Vierra, ALARA Coordinator Others j
- W. L. Curran, Cajun Electric Representative E, J. Ford, Senior Resident Inspector, NRC
- W. B. Jones, Resident Inspector, NRC
- Denotes those individuals present at the exit interview on December 22, 1989, i
The inspector also interviewed several other_ licensee employees including
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radiation protection,'radwaste, chemistry, training, and administrative
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personnel.
2.
Licensee Action on Previously Identified Inspection Findings
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i (Closed) Open Item (458/8917-03):
Very High Radiation Area Controls -
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This item was previously discussed in NRC 'itespection Report 50-458/89-17 and %volved the use of very high radiation area controls at the drywell l
.acc0:t ha tc h.- The licensee had revised the station paocedure for control of very high radiation areas which are contained inside large areas. The
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licensee presently is using warning ropes and battery powered flashing l
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'ights. The licensee's program addresses the matters discussed in NRC Information Notice 88-79.
(0 pen) Open Item (458/8917-04):
High Plant Dose Rates - This item was previously discussed in NRC Inspection Report 50-458/89-17 and involved the unexpected high radiation levels encountered throughout the drywell and reactor containment during Refueling Outage No. 2.
The licensee had established a Source Term Task Force which had been assigned the task of reviewing plant conditions and recommending a course of action to control and reduce the radiation levels. This matter was discussed during a meeting held in the Region IV office.on January 26, 1990, This item
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remains open pending NRC review of the licensee's Source Term Task Force report.
3.
Inspector Observations
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An inspector observation.is a matter discussed with the licensee during o.-
after the exit interview.
Observations are neither violations, deviations, nor unresolved items. They have no specific regulatory requirement, but are suggestions for the licensee's consideration.
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a.
Training for Radiation Protection Supervisors - There is no formal training program for radiation protection supervisors and professionals.
(See parayraph 6)
b.
Training Instructor /Ldiation Protection Plant Tours - Training I
. instructors are directed to spend 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a month at the plant.
Instructors are spending time at the plant; however, these l
instructors.are not spending this time observing work being performed in the radiologically controlled areas'of the plant in order to keep updated on health physics activities.
(See paragraph 6)
c.
Verification of Computer Input Data - The licensee did not have a program to verify that the data entered into the personnel dosimetry
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computer file was accurate.
O paragraph 7)
.d.
Airborne Radioactivity Mon:t, _rg - The licensee was utilizing the minimum number of constant m.aonitors to alert personnel of increased airborne concentrat4ns in work areas of the plant.
(See paragraph 8)
4.
Audits and Appraisals The inspector reviewed reports of audits, appraisals, and surveillances
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conducted by the licensee, including those audits required by Technical Specification (TS) 6.5.3.8.
The inspector reviewed selected portions of licensee QA audits and
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surveillance-reports for 1989.
The licensee had used technical specialists to supplement the QA department personnel during the performance of.the 89-09-1-HPRP, Health Physics / Radiological Protection Y.
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Progra, Audit core,eted in September 1989.
The licensee's QA auditi urveillance program appears adequate to determine compliance with station procedures.
The inspector also reviewed the following surveillances:
Su veillance Title Number 05-89-02-18 Health Physics and Personnel Monitoring 0S-89-01-35 Radiological Protection Services 05-89-03-20 Monitor Activity - RCA Control l
05-89-03-26 ALARA Program - ALARA Preplanning 05-89-03-41 Temporary Shielding Installation in the Drywell
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05-89-04-24 Radiation Protection Plan OS-89-05-03 Investigation of Quality Concerns Involving Radiation Protection Services The licensee's surveillances are directed toward procedural compliance and
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appear acceptable. The inspector noted that the audits did not include a technical evaluation of the adequacy of the implementing procedures or address identified program weaknesses.
No violations or deviations were identified.
5.
Radiation Protection Program The inspector reviewed program changes made since the previous inspection concerning organization, personnel, facilities, equipment, and procedures
that could affect the radiation protection activities.
The licensee had not made any major changes to the radiation protection program.
L The licensee has maintained a stable radiation protection organization
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l with less than a 10 percent personnel turnover during 1989.
The J
procedures reviewed during this inspection are listed in the attachment to Gis report.
The radiation protection organization maintains a good working
relationship and communications with other work groups.
These work groups, maintenance operations, radiation protection, and radwaste appears
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to discuss problems that could make their respective work performance more
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No violations or deviations were identified, t
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I 6.
Training and Qualifications
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The inspector reviewed the training and qualifications programs for the radiation protection staff and radiation workers to determine compliance with 10 CFR Part 19 and agreement with the recommendations of NRC Regulatory Guides (RG) 8.27 and 8.29.
The review included assignment of responsibilities, policies, goals, methods, and qualifications of newly hired or promoted radiation protection personnel.
The inspector determined there had not been any significant changes to the
. general employee training, training requirements for radiation protection technician, or training provided to radiation workers. A well defined training and qualification program had been established for radiation protection personnel at the technical level; however, a formal training and qualification program had not been defined or established for supervisors or professionals.
The inspector noted that the licensee had been able to provide indepth systems training to a limited number of radiation protection personnel by scheduling these individuals to attend select nuclear equipment operator training classes.
This has resulted in these individuals having a much better understanding of system
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radiological interfaces.
Radiological training instructors spend about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> each month in the plant as part of their routine work assignments.
However, the inspector noted that this in plant time is not spent observing ongoing work activities at the job site.
It appeared that these instructors were not observing actual work practices in order to relate their training sessions to actual work situations.
No violations or deviations were identified.
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7.
External Exposure Control The licensee's external radiation exposure control program was reviewed
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for agreement with commitments in Section 12 of the USAR; and compliance with the requirements of TS 6.8, 6.10, 6.11, and 6.12; 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409; and the recommendations contained in NRC RGs 8.8, 8.13, 8.14, and 8.28.
The inspector reviewed licensee's external exposure control and pu sonnel dosimetry programs, including changes to facilities, equipment, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; and required records, reports, and notifications.
Exposure ruords of plant and contractor personnel for 1989 were reviewed.
No exposures greater than 10 CFR 20.101 limits were identif t M.
The licensee had documented approximately 135 incidents of perst.v1 skin contamination during 1989.
In all cases, the contamination was successfully removed by normal decontamination methods.
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The inspector discussed with licensee representatives the quality control measures used to verify that data being entered into the computerized record keeping sy S m was accurate. The inspector observed that the licen.ee does not presently employ any quality control methods to assure data iaput accuracy.
The licensee stated during the exit interview on December 22, 1989, that they would review the inspector's observation.
No violations or deviations were identified.
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8.
Internal Exposure Control The inspector reviewed the licensee's internal exposure control program to determine compliance with 10 CFR Parts 20.103 and 20.405.
The review
included facilities, equipment, personnel, respiratory protection
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training, and procedures affecting internal exposure control, planning and preparation for ndntenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
The licensee has maintained an aggressive cleanup / decontamination program
that results in only between 4 and 5 percent of the radiologically I
controlled area requiring protective equipment for entry.
This also reduces the respiratory equipment usage and results in hss tima required to perform a particular work evolution and, consequently, ~ reduces the person-rem exposure.
The inspector noted that the licensee had a minimum number of constant air monitors (CAMS) in operation during this inspection. The licensee had two of the four fixed CAMS and two of the five available portable type CAMS in operation. The inspector discussed with licensee representatives.that although the four operational CAMS meet commitments contained in the USAR, Section 12.3.4.2.5 and 12.3.4.4, it appeared that there were several plant locations that are high traffic areas where the potential for airborne releases exist, but CAMS were not located in these areas. The licensee had not conducted a recent evaluation of their current air monitoring program to ensure that enough CAMS are strategically placed to immediately alert personnel of increased airborne concentration due to
. releases from plant systems.
The licensee has made changes to the USAR since it was first acceptec' by the NRC; however, there has been no change to the placement and operation i
of the inplant airborne monitoring program.
The original Safety Analysis Report as approved by the NRC accepts the minimum program that the
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licensee commits to have in place.
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No violations or deviations were identified.
9.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring The inspector reviewed the licensee's control of radioactive materials and contamination, surveys, and monitoring program, including audits and
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appraisals, changes, area radiation and airborne radioactivity monitors, portable survey and contamination monitoring instruments, protective clothing and equipment, surveys and monitoring, and radioactive material and contamination control orogram for compliance with 10 CFR Parts 20.5, 20.201, 20.203, 20.205, 20.207, and 20.301.
The inspector reviewed Condition Report 89-1046 dated September 20, 1989, which involved the receipt inspection of a trailer which had empty placards affixed to the external surfaces, but was found to conta,a a 55 gallon drum inside. A radiological survey of the trailer and drum exhibited radiation levels of 150,000 disintegrations per minute (dpm) per
probe volume (approximately 70 square centimeters (cm ) by direct frisk and 30,000 dpm/100.cm2 loose contamination.
The trailer floor was decontaminated by removal of a 14-inch by 12-inch and 1-inch thick area and the 55 gallon drum was placed in an overpack and labeled as a Radioactive I container.
it appears that the proper procedures were followed for the decontamination of the trailer and transport of the drum back to the owner.
It should be noted that the licensee did not allow the trailer inside the protected area prior to mding all.the necessary notifications and resolving the prob'em.
The inspector also reviewed the circumstances and action taken relating to Condition Report 89-1068, which involved an individual who exited a high radiation area (HRA) through a posted very HRA on September 28, 1989. The licensee-submitted an informational report to the NRC on October 27, 1989, regarding this matter.
On September 29, 1989, a field engineer accompanied by two maintenance personnel entered the reactor core isolation cooling system cubicle, a posted HRA, under an approved radiation work permit (RWP). When these individuals attempted to leave the area, the latch to the watertight door, used to enter the area,-would not release, and therefore they could not open the door. There was no means fo. communication available in this area. The engineer instructed the maintenance personnel to remain at the 70-foot elevation door while he exited the area via a door on the 95-foot elevation. The stairway leading from the 70-foot to 95-foot elevation had a barrier with a flashing light at the 78-foot elevation denoting that a very HRA axisted in piping on the 95-foot elevation. The engineer crossed the barrur rope into the very HRA, exited the door on the 95-foot elevation, opened the watertight door on the 70-foot elevation, allowing the maintenance personnel to leave the HRA, after which he informed radiation protection of the occurrence. The total exposure recorded on pocket dosimeters indicated each individual received 10 millirem. The engineer was not aware of what the exact radiation level was in the eraa designated "very HRA" prior to his entry.
He was equipped with a continuously integrating dose meter with a preset alarm watch that was a requirement for entry into the HRA. A later radiation survey, performed to answer questions raised by the inspector, indicated the route travelled by the engineer did not expose him to very HRA levels. The inspector noted the licensee has two designations, very high radiation area, and very high radiation exclusion area.
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-9-t have distinctive markings and the later identifies an area where potentially hazardous radiation levels may exist. The area entered was not an exclusion area.
Tachnical Specification 6.12.2 states, in part, that entry into a very HRA requires that the individual enter on an approved RWP that specifies dose rate levels and the maximum stay time or continuous surveillance by personnel qualified in radiation protection procedures.
The September 28, 1989, incident is considered to be a violation of TS 6.12.2.
However, the licensee's actions in taking prompt remedial measures making a full evaluation and report, and the instituting of corrective actions to prevent a recurrence met the criteria of the NRC enforcement policy in 10 CFR Part 2, Appendix C (1989) for a licen ee-identified violatior.
Therefore, a Notice of Violation will not be issued for this violation.
The inspector noted the licensee had increased the sensitivity of the portal monitors located in the security building. The licensee has lengthened the counting time by requiring persornel to stop for a few seconds before exiting the portal monitor.
The inspector discussed with licensee representatives the unexpected high radiation levels that were encountered during Refueling Outage 2 and what actions that were being taken to control and reduce these radiation levels.
NRC Inspection Report 50-458/89-17 discusses the NRC concerns identified during the April 9-19, 1989, inspection.
The licensee was also aware at that time that radiation levels were significantly higher than expected.
The licensee observed higher dose rates than initially expected during Refueling Outage No. 2.
Table 1 depicts tiie dose rates observed at select locations in the drywell, auxiliary building, and steam tunnel during Refueling Outage No I and No. 2.
These systems account for a majority of the person-rem exposure during a major plant outage.
Table 1 Refueling Refueling Location System Outage-1*
Outage-2*
Drywell Reactor (RX) Recirc Risers
300 Drywell RX Recirc Pump Suction 200 500 Drywell RX Recirc Pump Disch 110 225 Drywell Reactor Water Cleanup (RWCU)
110 850 Ring Header
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Refueling Refueling Location System Outage-la Outage-2*
Aux Bldg RWCU Pump 250 400
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Aux Bldg Residual Heat Removal (RHR)
110 Heat Exchanger Stm Tunnel RWCU Lines 500 1,200
- mrem /hr general area 18-inch readings Thelicenseemadeatelephonesurveyin$eptember1989andobtained radiological data from six other boiling water reactor facilities. The licensee concluded that their radiation ievels were generally above the
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L radiation levels observed at other facilities.
During the January 26, 1990,-management meeting held at the Region IV office, the licensee stated that a followup evaluation of the survey data performed in January 1990 indicated that River Bend Station's radiation levels were consistent with other BWR-6 sites. The results of the September survey are contained in Attachment 2.
The information furnished to the inspector by.icensee u presentatives during the inspection indicated that plant macejement w w not aggressively pushing for a resolution of the problem pertaining to radioactive crud being deposited throughout the reactor system in the containment, radwaste, and auxiliary building.
The slow, cautious approach by the licensee was perceived by the inspector that RBS had not
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devoted sufficient attention to this matter.
It was stated to the
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inspector.that no action would be taken until af ter Refueling Outage 3 which is scheduled for late 1990 and that the midcycle outage would be used to track radiation levels at specific plant locations. The licensee also stated they had used the maximum amount of temporary shielding they could safely use during Refueling Outage 2 and that Refueling Outage 3 work would progress irrespective of the radiation levels encountered.
After the April 9-19, 1989, inspection, the licensee established a Radiation Source Term Task Force which is comprised of members from chemistry, radiological services, engineering, operations, cost systems, and projects departments. Based on commitments made in the January 26, 1990, meeting, the licensee plans to issue a report by the end of February 1990'with recommended actions.
During the management meeting of January 26, 1990, tm ticensee presented an extensive scenario of events by the Radiation Scorce Term Task Force to resolve the radioactive crud problems at RBS. This was more information than was provided to the inspector during the inspection and provided the NRC with a better understanding of the licensee's plans to reduce these high radiation levels.
Ao deviations were identified.
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1 10. Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including:
the ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; worker awareness and
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involvement in the ALARA program; and establishment of goals and objectives, and effectiveness in meeting them.
i The inspector reviewed the ALARA organization, the qualifications and experience of its members, and the effectiveness of the organization in-continuing to institute dose saving programs. The licensee had relied on the use of temporary shielding to reduce dose rates during the last outage.
The license originally established a goal for 1989 of 325 person-rem, but J
expended 528 person-rem. The reason for the larger exposures was the result of the higher than expected radiation levels and increased work scope performed during Refueling Outage No. 2.
In general, the ALARA organization is an aggressive, effective group as illustrated by the feedwater sparger and in-service inspection of nozzles work that was performed during Refueling Outage No. 2.
The licensee was able to maintain a low-radiation exposure for this work through the use of mockup training, temporary shielding, and personnel controls. The ALARA-organization receives strong support from all levels of management.
However, it did not appear that the ALARA group had exercised effective controls and oversight of some maintenance activities.
For examples, maintenance activities on MSIV work had resulted in the introduction of large amounts of stellite (1.25-1.5 pounds) into the reactor coolant system.
It appeared that maintenance workers-had received limited training alerting them to the radiation problems caused by stellite being activated and that the ALARA group had not played an active role in verifying that the job site was free of debris after completion of MSIV maintenance work.
No violations or deviations were identified.
11.
Exit Interview The inspector met with the resident irspector and the licensee's representatives denoted in paragraph 1 at the conclusion of the inspection on December 22, 1989, and summarized the scope and finding; of the inspection as presented in this report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during the inspection, l
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ATTACHMENT 1 TO NRC INSPECTION REPORT 50-458/89-44 DOCUMENTS REVIEWED Title Revision Date Administrative Procedures (ADM)
ADM-0007 Selection, Training, Qualification, and
8/18/88 Evaluation of Plant Staff Personnel
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'ADM-0025-Conduct of Radiation Protection Services
3/27/89 ADM-0039 ALARA Program
3/21/89
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Radiation Section Procedures (RSP)
RSP-0003 Personnel Qualification for the Radiation
11/7/89'
Protection Section RSP-0009 ALARA Program Implementation
6/23/89 RSP-0200 Radiation Work Permits
3/14/89 Radiation Protection Procedures (RPP)
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RPP-0005 Posting of Radiologically Controlled Areas
2/17/89 j
RPP-0006 Radiological Surveys
7/10/89 RPP-0013-Survey / Instrument Response Testing
6/15/88 '
RPF-0022 Respiratory Protection Equipment, Cleaning,
6/20/89-Inspection, and Repair
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