ML20034E954
| ML20034E954 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 02/19/1993 |
| From: | Kozak T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20034E939 | List: |
| References | |
| 50-331-93-03, 50-331-93-3, NUDOCS 9303020118 | |
| Download: ML20034E954 (9) | |
See also: IR 05000331/1993003
Text
{{#Wiki_filter:. . . . . . . ! U.S. NUCLEAR REGULATORY COMMISSION
REGION III Report No. 50-331/93003(DRSS) Docket No. 50-331 License No. DPR-49 - Licensee: Iowa Electric Light and Power Company . IE Towers P. O. Box 351 , Cedar Rapids, IA 52406 ' Facility Name: Duane Arnold Energy Center ' Inspection At: Duane Arnold Site, Palo, Iowa Inspection Conducted: January 11-15, 1993 and January 27 - February 10, 1993 h. W Inspector T. J. Kozak / [[
Senior Radiation S etialist Ddte / , f- Approved B - Wil iam G. Snell, Chief //7b Radiological Controls Section 2 ste/ Inspection Summary: Inspection on January 11-15. 1993 and January 27-February 10. 1993 (Report ' No. 50-331/93003fDRSS)) Areas Inspected: Routine announced inspection of the licensee's radiation protection program, including: licensee actions on previous inspection findings; refueling floor operations; planning and preparation; solid radioactive waste; external exposure control; control of radioactive material , and contamination, surveying and monitoring; and maintaining occupational t exposure as-low-as-reasonably achievable (ALAP,A) (Inspection Procedures (IP)
83750 and 86750). Results: The licensee's radiation protection program appears to be generally effective in controlling radiological work and in protecting the public health and safety. One violation was identified associated with the unauthorized ! storage of a highly radioactive stellite bearing in the cask pool. ' One non-cited violation was identified associated with an unauthorized entry by an , operator into a posted high radiation area. The licensee' exhibited improved - performance with regard to dose expended and personnel contamination events in 1992. Source term reduction remained a strength in 1992-and plans were to continue source reduction efforts in 1993. Excellent performance was noted. a during the removal of an intermediate range monitor from the reactor vessel. ! e 9303020118 930219 PDR ADOCK 03000331 G PDR ,
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. ' I DETAILS ' . 1. Persons Contacted Licensee Staff l l ' l
- D. Boone, Supervisor, Health Physics
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- P. Bessette, Regulatory Communications Supervisor
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- D. Blair, CA Assessment Supervisor
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- D. Eilers, ALARA Specialist
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- P. Louis, Health Physics Foreman
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- R. Hite, ALARA Coordinator
- W. Holden, Training
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- L. Kriege, Chemistry Supervisor
- R. Perry, ALARA Specialist
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- K. Peveler, Manager, Corporate QA
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- D. Robinson, Regulatory Communications
- D. Schebler, Supervisor, Radioactive Waste
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- R. Schlueter, Health Physics Foreman
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- M. Teply, Refueling Floor Supervisor
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- J. Thorsteinson, APS - Operations Support
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- E. Wienola, QA Specialist
0* T. Wilkerson, Manager, Radiation Protection
- D. Wilson, Plant Superintendent
0*#K. Young, Manager, Nuclear Licensing Nuclear Reaulatory Commission
i C. Miller, Resident Inspector
- M. Parker, Senior Resident Inspector
The inspector also interviewed other licensee personnel in various departments during the course of the inspection.
- Denotes those present at the interim exit meeting on January 15, 1993.
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- Denotes those present at the interim exit meeting on January 29, 1993.
l 0 Denotes those present at the exit meeting conducted by telephone on February 16, 1993. 2. General l This inspection was conducted to review aspects of the licensee's radiation protection program. Included in this inspection was a ' followup of outstanding items in the radiation protection area. The inspection included tours.of radiologically controlled areas, the reactor building, and radwaste facilities, observations of. licensee activities, a review of representative records and discussions with licensee personnel. ] 2 , l ,
. . 3. Licensee Action on Previous Inspection Findinas (IP 83750) (Closed) Violation (331/92007-01): Failure to p. ovide adequate instructions to two workers concerning radiation levels, dosimeter alarms, and response to dosimeter alarms as required in 10 CFR 19.12; failure to provide adequate surveys of radiological conditions- as required in 10 CFR 20.201. The licensee performed an extensive review of their controls for work in high radiation areas, including work during vessel draindown evolutions, and have instituted what appears to be adequate controls to prevent a similar event from occurring. Employee training was upgraded to include descriptions of alarming dosimetry and the proper reaction to alarms. This item is closed. 4. Refuelina Floor Operations (IP 83750) During the inspection, the inspector reviewed the circumstances surrounding the discovery of a highly radioactive control rod bearing stored in the Cask Pool without proper authorization. The following is a description of the events leading up to the discovery of the bearing and subsequent corrective actions. In August 1992, the Duane Arnold Energy Center (DAEC) resident inspectors (RIs) reviewed spent fuel pool storage practices and documented their findings in Inspection Report No. 50-331/92012. It was determined that Administrative Control Procedure (ACP) 1407.2, " Material Control in the Spent Fuel Pool and Cask Pool", requires that a Fuel Storage Pool / Cask Pool Storage Permit be initiated and approved for each item, other than tools, that will be stored in the Spent Fuel Pool (SFP) or Cask Pool (CP). This procedure also prohibits the storage of items with contact dose rates greater than 35 Rad per hour in the CP. During. the inspection, several tools and other objects were found to be suspended from the SFP railing over the spent fuel. These items were normally stored in the CP but had been temporarily relocated to the SFP because of the SFP cleanup project. The licensee indicated that the items would be moved back to the CP after the project. During the first week of January 1993, the RIs did a followup inspection of the SFP. It was determined that the items had yet to be moved to the CP and were still suspended in the SFP. On January 11, 1993, the licensee went to the area to assess the situation. During their assessment, the licensee discovered that a fastening device for a control rod grappling tool had broken causing the tool to fall and wedge between a spent fuel rack and the SFP wall. A visual inspection was performed during which it was determined that no fuel damage had occurred. The RIs were then notified of the fallen tool. In the initial review of the situation, the RIs noted that the licensee had not - given appropriate attention to the dropped tool and the potential for damage. Neither the operation's shift supervisor or the radiation protection supervisor had been informed of the event, methods to detect fuel damage, including underwater inspection of the nearby fuel bundle, had not been taken or planned and a deviation report had not been written. The licensee subsequently took appropriate action to address 3
. ' the RIs concern in these areas. On January 13, 1993, the. region-based inspector toured the area and noticed several nylon ropes attached to the CP railing and inquired about what was hanging from them. In response to the above concerns, the licensee developed a course of- action which included an inventory of the SFP and CP. The inventory was performed on January 18, 1993. During the inventory, a bucket suspended by a nylon rope from the CP railing was found to contain a stellite control rod bearing. The dose rate on the bucket, which was suspended ' approximately 10 feet below the water surface, was determined to be greater than 20,000 Rad per hour. A handwritten note was attached to j the rope which stated, " Caution, Stellite Ball, Contact HP Prior To Moving." , i Technical Specification 6.8.1 requires that written procedures involving
nuclear safety, including applicable check-off lists and instructions for preventive and corrective maintenance operations which could have an , effect on the nuclear . safety of the facility be prepared, approved, ' implemented, and maintained. Administrative Control Procedure 1407.2, , " Material Control in the Spent Fuel Pool and Cask Pool", implements this
requirement by requiring a Fuel Storage Pool / Cask Pool Storage Permit to be initiated and approved for each item, other than tools, that will be . stored in the fuel Storage or Cask Pool. This procedure also prohibits ! the storage of items with contact dose rates greater than 35 Rad per i hour in the Cask Pool. ' Contrary to the above, on September 4, 1992, workers did not initiate a Fuel Storage Pool / Cask Pool Storage Permit or obtain approval prior to storing a stellite bearing from a control rod blade in the Cask Pool. Further, the stellite bearing had contact dose rates greater than 20,000 Rad per hour. This is a violation of ACP 1407.2. (Violation No. 331/93003-01) Both the SFP and CP have large signs attached to the railings stating that nothing should be lifted out of either pool without health physics coverage. In addition, several portable and permanent radiation monitoring devices were in the area which were set to alarm at various levels, the lowest being 10 millirem per hour. The inspector reviewed procedures in place for work involving divers in the SFP and CP and verified that requirements were in place to perform surveys in the work area prior to entry. These controls would most likely have led to appropriate actions to prevent an overexposure if the bearing had been inadvertently lifted above the pool surface or if diving operations were conducted in the CP. The bearing was subsequently moved to the SFP and stored on the SFP floor in an unattached bucket along with the other 223 bearings which had been removed from control rod blades during the past- two SFP cleanup projects. The stellite bearing found in the CP was placed there during the week of September 1, 1992. The SFP cleanup project, which had been managed well up to this point, was nearing an end and the licensee was disposing of waste which had been stored in the SFP since the last cleanup project in 4
, -) l- . . - , l 1990. During that project, the licensee disposed of 20 control rod l blades. The stellite bearings were removed from the blades and stored.
l in the SFP. One of the bearings was lost in the SFP during removal and ' it was thought by the licensee that it remained under the spent fuel i ' racks._ However, it appears that the contractor had retrieved the bearing and placed it in a hopper on the bottom of the SFP with other scraps from the project. The hopper remained in storage until the 1992- cleanup project during which its contents were targeted for disposal. i On or around September 1,1992, the contents of the hopper were dumped, under water, .into a disposal liner. Upon surveying the liner, the licensee found an unexpected hot spot of approximately 1,500 Rad per
i hour. Efforts to identify the source of the hot spot resulted in .
l retrieving the lost stellite bearing on September 4, 1992. The key l personnel in charge of the cleanup project had left for the holiday weekend and were not present at the time the bearing was retrieved. In order to move the bearing to the SFP, the CP/SFP gate had to be removed. The hanger for the CP/SFP gate was damaged so there was no place to hang I the gate once it was removed. However, the gate could have been suspended in the pool while the bearing was moved to the SFP. It was l decided to place the bearing in a bucket suspended by a nylon rope from l the CP railing. Technicians wrote'the words mentioned above on a small tag and attached it to the rope. No. storage permit was initiated nor I was there approval obtained to store the bearing in the CP as required
in ACP 1407.2. Following the holiday weekend, the project manager ' ' returned, asked where the bearing was stored and was told that it was in. the bucket. He assumed that this meant the bearing was placed in the i bucket in which the other bearings were stored on the bottom of the SFP ' ~ , I and did no further questioning. No further action was taken until the-
bearing was found on January 18, 1993. r The licensee acknowledged that they did not have appropriate control of.
the bearing. In addition to relocating the bearing to the SFP along with the other bearings, planned corrective actions included a thorough " l review of the circumstances surrounding this event and incorporation of I the findings in a lessons learned file for future cleanup projects. l Their review will also encompass their reaction to the fallen tool and
their SFP/CP tool storage policy. At the time of the inspection, there were no formal requirements for control of tools stored in either pool. , The results of the licensee's investigations will be reviewed during future inspections. l One violation was identified. l ' ' 5. Plannina and Preocration (IP 83750. 86750) ' The inspector reviewed licensee preparations for radiological work during a forced outage. The job with the highest radiological liability j was the removal of Intermediate Range Monitor (IRM) B which was observed l by the inspector. This job was performed extremely well especially l considering the short time available for preparations. The Radiation Protection Department has become more involved in the
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. - . - < , t planning process since the last inspection. The licensee conducts a ! six-week look ahead meeting where all major work items are identified , and scheduled. RP has become an integral part of this meeting and is now conducting an in-house meeting with their supervisors to discuss I upcoming work and develop a schedule so' that resources will be appropriately allocated. This approach appears to have been effective in improving planning and communications between departments. l i l No violations or deviations were identified. L i 6. Solid Radioactive Waste (IP 86750) ~ The inspector reviewed the licensee's-solid radioactive waste management program, including: changes to equipment and procedures, processing and control of solid wastes, adequacy of required records, reports and
notifications, performance of process control and quality assurance
programs and experience in identification and correction of programmatic , i I weaknesses. . There were no major changes to the radioactive waste processing program since the last inspection. The licensee shipped for burial , approximately 2,900 cubic feet of' dry active waste (DAW) and 1,450 cubic
feet of resin in 1992. This was below the licensee's initial estimate , and represents a relatively small volume for a boiling water reactor (BWR). The licensee plans to ship for burial all of the waste they ' generate for the next 18 months and has estimated their total disposal
volume for that period to be approximately 6,000 cubic feet. No violations or deviations were identified. 7. External Exposure Control (IP 83750) The inspector reviewed the licensee's external exposure control and personal dosimetry program, including: changes in the program, use of dosimetry to determine whether requirements were met, and required , records, reports and notifications. The licensee changed radiation dosimetry service vendors starting in January 1993. The specifications presented for bid included lowering the limit for detection, upgrading the processing systems, and increasing the efficiency. The exposure report, which will be provided quarterly, will include deep dose, eye dose, shallow dose, extremity . ' dose, cumulative dose, and neutron dose _ as applicable. The inspector verified that the vendor was National Voluntary Laboratory Accreditation , Program (NVLAp) accredited to process dosimeters in categories I through i VIII. Total station dose as measured by thermoluminescent dosimeters was 502 person-rem in 1992, including 413 person-rem for the spring. ! refueling outage. This represents a relatively high total dose for a BWR but was a substantial improvement from the previous outage year and ] was below their yearly goal. The goal for 1993 was established'at 470 - ' person-rem of which 390 was expected to be expended during the scheduled
refueling outage. This goal did not take into consideration dose which l 6 l
. will be expended during motor operated valve testing which is required , by Generic Letter 89-10. , On February 1,1993, the _ licensee was draining the CP prior to repairing a hanger in the pool. During the draining evolution, an. operator involved with the evolution noticed' that the skimmer surge tank level was rapidly decreasing. The procedure used for CP draining did not have a contingency for this condition. The fuel pool cooling water pump trips on low skimmer surge tank level and a potential exists for fuel pool water to enter the reactor building ventilation system. The operator reacted by opening a valve from the condensate system to increase the skimmer surge tank level. The valve was located inside a high radiation area and the operator did not have'a radiation monitoring device to indicate the dose rate in the area, an alarming dosimeter, or a technician to accompany him in the area. He was aware of this fact but he felt that the condition required prompt attention. He indicated that he would not have entered this area if he didn't feel that prompt attention was required. The operator was in the area for less than one minute and received no appreciable dose. Subsequent licensee review of this event revealed that the operator's actions were not needed in such a prompt nature to ensure plant safety. Entry into a high radiation area without a dose rate meter, an alarming dosimeter, or a qualified ! health physics technician with a dose rate meter is a violation of Technical Specification 6.9.2. During this inspection, certain of your activities, as described above, - appear to be in violation of NRC requirements. However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.1 of the " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 CFR l Part 2, Appendix C) were satisfied. l l One non-cited violation was identified. 1 8. Control of Radioactive Materials and Contamination. Surveys. and Monitorina (IP 83750) The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: maintenance and calibration of contamination survey and monitoring equipment; adequacy of review and dissemination of survey data; and effectiveness of radioactive and contaminated material controls. The inspector verified by a review of records, discussions with licensee personnel, and tours of operational areas that the supply, maintenance, and performance checks of survey monitoring instruments were adequate. The alarm for the Eberline PCM-1Bs used for whole body frisking throughout the plant was set at 5,000 disintegrations per second over the 300 square centimeter area of the detectors. The inspector- questioned licensee representatives about proper actions in case an alarm is received when frisking and was provided appropriate responses _ from each person queried. 7 !
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4 There were 294 Personnel Contamination Events (PCEs) recorded in 1992 of
which 184 occurred during the spring refueling outage. This is a significant performance improvement over that during the last outage , year and is attributable to increased investigative efforts by the licensee in this' area. These efforts included dedicating a technician 1 to investigate causes of PCEs, including an interview of each contaminated individual, and to make recommendations on how to reduce - their occurrences. A formal documenting and tracking system was set up
which identified several problem areas. The inspector indicated that
while the licensee's effort resulted in improved performance, continued i attention appeared warranted in this area to further reduce the number , of PCEs.
The inspector reviewed previous NRC concerns about the availability of_ [ radiation protection technicians on backshifts. During non-outage times, the licensee normally staffs the backshifts with one technician who is responsible for conducting shiftly surveys and providing job _ l . coverage, if needed. The licensee has recently initiated a policy that requires the backshift technician to wear a pager whenever.he is not at
the controlled area access point so that he can provide prompt response when needed at the access point or for job coverage. The inspector
verified that the technician was now readily available. l , No violations or deviations were identified. i 9. Maintainina Occupational Exposures ALARA (IP 83750) The inspector reviewed the licensee's program for maintaining
occupational exposures ALARA, including: the source term reduction ! program; ALARA group staffing and qualification; changes ~ in ALARA policy j and procedures, and their implementation; ALARA considerations for planned maintenance and refueling outages; and worker awareness and involvement in the ALARA program. j There were significant efforts expended in the source term reduction program during 1992. These efforts included a chemical decontamination of the recirculation system, the replacement of 32 high cobalt- containing control rod blades (18 were replaced on an accelerated l schedule) with low cobalt-containing blades, replacement of the feed pump recirculation valve internals with stellite-free parts, and I hydrolazing of tanks and pipes to reduce dose rates. Plans for 1993 include replacing the remaining 36 cobalt bearing control rod blades,. replacing 126 bundles of cobalt containing fuel, and- replacing the stellite internals of the feedwater regulating valves. A chemical decontamination of a portion of the recirculation system is also , I ' planned. No changes in staffing or policy occurred since the last inspection. j No violations or deviations were identified. . 8 l l .
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! - r . 10. Exit Metlin9 The inspector conducted interim exit meetings with-licensee -i representatives (denoted in Section 1) on January 15 and 29, 1993, and , conducted an exit meeting by telephone on February 16, 1993, to discuss the scope and findings of the inspection. i ' During these meetings, the inspector discussed the likely informational content of the inspection report with regard to documents or processes
reviewed by the inspector during the inspection. -Licensee ! representatives did not identify any such documents or processes as - proprietary. The inspector specifically discussed the following items: The violation associated with the unauthorized storage of a highly' '
i radioactive stellite bearing. The non-cited violation associated with an unauthorized entry into
a posted high radiation area. , .t The improved radiological performance with respect to dose
expended and contamination control in 1992 and the need to i continue these positive trends. l l The excellent performance while removing IRM B during the forced !
outage. ! ! , t ! l ! ! 1 i ! ! !
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