ML20042F390
| ML20042F390 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/23/1990 |
| From: | Baer R, Murray B, Nicholas J, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20042F383 | List: |
| References | |
| 50-313-90-04, 50-313-90-4, 50-368-90-04, 50-368-90-4, NUDOCS 9005080268 | |
| Download: ML20042F390 (30) | |
See also: IR 05000313/1990004
Text
__
_
_ _ _ _
_____
(
-',
v
APPENDIX C
,
W
U.S.'NVCLEAR REGULATORY COMMISSION
REGION IV
1
NRC Inspection Report:
50-313/90-04
Operating Licenses:
DRP-61
50-368/90-04
-
!
Dockets: .50-313
'
50-368
!
!
~
Facility Name: Arkansas Nuclear One (AW 3
Inspection At: AND Site, Russellville, Arkansas
<
-!
Inspection Conducted:
January 29 through February 2,1990
i
Inspectors:
"-
9D
_.l-
R. T. Baer, Team Leader, Radiation Specialist
Date
Facilities Radiological Protection Section
[f
&
&/ IO'
'.-B. Nicholas, Senior Radiation Specialist
Date
Facilities Radiological Protection Section
~
h3
D
-V'
Cw
. A. Paul, Senior Radiation Specialist
Date.
!
Facilities Radiological Protection Section,
[
Region III-
!
Approved:
i/)
l[AQ//o
](fate / h
i
_
B1
inE Kurray, L'hief, F
lities Radiological
i
Protection Section
1
Inspection Summary
Inspection Conducted January 29 through February 2, 1990 (Report 50-313/90-04;
10-368/90-04)
~
Areas _ Inspected:
Special, unannounced team inspection of the licensee's
radiological control program including:
radiation protection, radioactive
.
50?*R8880 gpas
psia
1
1
,
..
..
~2-
,
.
effluent releases, low-level radioactive waste, and transportation of
radioactive materials.
Results: The licensee has maintained a well aualified radiation
protection (RP) staff and additional technical support is available from the
corporate organization. A continual problem has been the lack of attention to
. detail which has resulted in-several violations. The licensee had installed an
'
improved state-of-the-art thermoluminescent dosimeter (TLD) system for external
radiation exposure determinations in addftion to personnel contamination
monitors and portal monitors for detection of radioactivity contamination on
personnel.
Management support and stat. ion personnel awareness to the ALARA program has
increased and all the work groups appear to be communicating well with each
7
other. The ALARA program needs additional attention in the areas of computer
4
support- for health physics (HP)/ALARA records and the tracking and trending of
radiological data.
'
>
The licensee's response to correct procedural inadequacies in some cases
appears very slow.
The radioactive waste management area is well documented and staffed.
. Violations which have occurred have.been the result of personnel errors. The
licensee has been responsive to NRC issues in most areas. The radioactive
effluents program appears to have adequate resources but continues to have
problems with releases being made in violation of' Technical
' Specifications (TS).
The licensee.-had devoted considerable attention to the RP program in an effort
to stop the declining trend noted-in 1988 and 1989.
Improvement had been made
in the. areas of organization changes, staffing, purchase of new health physics
equipment and instruments, and revisions of department procedures.
However,
1
the identification of several violations indicates that continued improvements
are needed.
'
Within the areas inspected, three inspector-identified violations
(paragraphs 11,14, and 15), one licensee-identified violation (paragraphs 12
,
and 15) included in the Notice of Violation, and one deviation.(paragraph 13)
were identified.
Three licensee-identified violations (paragraphs 12, 14, and
.15) were identified. The inspectors identified one unresolved item
'(paragraphs 8, 9 a'and 9.c) and one open item (puragraph 9.b).
Four previously
identified inspection findings were closed (paragraph 2).
_ - ..
.
-3-
j
-
DETAILS
1.
Persons Contacted
- N. S.-Carns, Director, Nuclear Operations
- D. W. Akins, Superintendent, HP Operations
- T. C. Baker, Technical Assistant
- E. E. Bickel, Manager, RP/Radwaste
- H. N. Bishop, Jr., Radwaste Supervisor
i
- D
W. Boyd, Licensing Specialist
l
- R. G. Carroll, HP Specialist
- 0
W. Cypret, HP Specialist
- J. J. Fisicaro, Manager, Licensing
- M. E. Frala, Nuclear Chemistry Supervisor.
- R. D. Gillespie, Temporary Manager, Central Maintenance
- R. E. Green, HP Technical Support Supervisor
- L W. Humphrey, General Manager, Nuclear Quality
- G. T. Jones, General Manager, Engineering
- W.- C. McKelvy, Acting Chemistry Manager
- R. A. Sessoms, Manager, Central Operations
,
- Denotes those1 individuals present at the exit meeting conducted on
February 2, 1990.
The inspectors also interviewed other licensee personnel during the
1
inspection from the.following departments:
chemistry, maintenance,
!
operations, RP, radwaste, quality assurance (QA), and corporate HP,
2.
F_gliowup on Previous Inspection Findings
(0 pen) Open Item (313/8914-03; 368/8914-03):
Semiannual Ef fluent Release
Report Dose Data Format - This item was previously discussed in NRC
. Inspection Report 50-313/89-14; E0-368/89-14 and involved the annual
summary of radiation doses resulting from radiological effluents in a
format in the semiannual effluent release reports which would readily
-indicate to the reader compliance with TS requirements.
The inspectors
reviewed the draft radiation dose data summary for 1989 that was to be
included in the third and fourth quarter 1989 semiannual effluent release
report due to be issued in March 1990 and found the format acceptable.
This item will remain open pending NRC review of the published third and
fourth quarter semiannual effluent release reports.
(0 pen) Open Item (313/8936-03; 368/8936-01): Classification of Placement
of Personnel Monitoring Devices for External Exposure - This item was
previously discussed in NRC Inspection Report 50-313/89-36:, 50-368/89-36
and involved the misinterpretation of NRC Information Notice (IN) 81-26 in
that the licensee included the lower leg to be monitored as an extremity.
The licensee had revised Procedure 1000.031 to reflect the lower leg to be
i
-
4
o!-
,'
,-
'
-4-
included as part of the whole body; however, the licensee had not
corrected Section 8.26 of Procedure 1642.006 to reflect this change.
This
item will remain open pending further NRC review.
(Closed) Open Item (313/8936-02; 368/8936-02):
Placement of Self-Reading
Dosimeters (SRDs) - This item was previously discussed in NRC Inspection.
Report 50-313/89-36; 50-368/8?-36 and involved personnel wearing SRDs
inside of their protective clotning and making it difficult for workers to
t
retrieve and read these devices. The licensee had provided written
,
instructions for the correct placement of the_SRDs.
(Closed) Open Item (313/8936-03; 368/8936-03):
Skin Exposure - This item
-
was previously discussed in NRC Inspection Report 50-313/89-36;
5U-368/89-36 and involved the evaluation of a hot particle skin exposure.
The licensee's investigation of this event conc?uded that the cause of the
hot particle attachment to the skin was improper clothing removal and
inadequate hot particle controls. The inspectors reviewed the licensee's-
dose assessment and verified that doses were in agreement with the
assigned dose to the individual.
(Closed) Open Item (313/8936-04; 368/8936-04):
Contamination Incidents -
'
This item was previously discussed in NRC Inspection Report 50-313/89-36;
50-368/89-36 and involved the licensee's performance in reducing the
!
number of personal contamination events (PCEs).
The inspectors reviewed
1
l
the actions taken by the licensee and noted a significant reduction in the
number of PCEs.
These activities'are discussed in paragraph-9.c.
,
(Closed) Open Item (313/8936-05; 368/8936-05):
Respiratory Protection
Procedures - This item'was discussed in NRC Inspection
Report 50-313/89-36; 50-368/89-36 and involved radiological control
weaknesses observed by an inspector-in the use of respirators and
protective clothing. The licensee's HP staff had issued written
instructions to all RP technicians and the onsite staff concerning these-
matters.
The inspectors reviewed these instructions and determined that
they adequately addressed the observed weaknesses.
3.
Unresolved Item
An unresolved item is a n:atter about which more information is required to
ascertain whether it is an acceptable item, a deviation, or a violation.
The following unresolved item was identified:
Unresolved Item
Title
paragraph
l
313/9004-06
Portal Monitor Alarms, Radiation
'
368/9004-06
Controlled Area (RCA) Exit Controls,
and Contamination Release Limits
8, 9.a, 9.c
,
,
_
1[
'
i
'
.
I
-5-
1
l
'
1
,,
4.
Open Items Identified During This Inspection
]
l
An.open item is a' matter that requires further review and evaluation by
1
the inspectors'.- Open items are used to document, track, and ensure
i
adequate followup on matters of concern to the inspectors.
The following
open item was identified:
1
Open Item
Ti t _i_ e
Paragraph
I
313/9004-07
Contaminated Tool and Equipment
1
368/9004-07
Controls
9.b
j
i
5,
Followup on Licensee Event Reports (LER)
1
(Closed) LER (368/89-021):
Inoperable Liquid Effluent Radiation Monitor
)
Resulting in an Unmonitored Radioactive Liquid Release - The event
i
described in LER 368/89-021, dated December 11, 1989, involved the release
)
of radioactive liquid effluent through an unmonitored discharge flowpath.
,
The facts describing the event and the licensee's corrective actions are
!
discussed in paragraph 14. The inspectors reviewed the' licensee's
I
corrective actions and determined them to be adequate.
4
i
(Closed) LER (313/89-032):
Failure to Perform the Reactor Building Area
Radiation Monitors' Monthly Surveillance Test - The event described in-
LER 313/89-032, dated October 6, 1989, involved the. failure to perform the
i
TS required monthly functional test on the Unit I reactor. building area
j
radiation monitors. The new procedure for performing the monthly
q
functional test on the Unit 1 area radiation monitors was not added to the
t
Master Test Control List (MTCL)'used.to schedule and track the TS testing
- !
!
requirements.
The facts describing the event and the licensee's
'
corrective actions are discussed in paragraph 14. The inspectors reviewed
y
the licensee's corrective actions and determined them to be adequate.
~
6.
Organization and Management Controls
i
The inspectors reviewed the licensee's onsite RP organization, staffing,
and assignment of responsibilities to determine agreement with the
commitments-in Chapters 12 and 13 of the Units 1 and 2 Updated Safety
Analysis Reports (USARs) and compliance with the requirements in Section 6
1
of the Units 1 and 2 TSs.
.
.The licensee had made several changes to its organizational structure
4
during the past year to improve performance in the RP area and was in the
process of making another change during the inspection.
Previous changes
were in personnel assignments above the position of station radiation
protection manager (RPM), while the current change was directed toward the
method of operation within the work groups.
.
.
.
.
-6-
.
.
The RPM presently reports to the central plant manager as does the
managers of central support (maintenance) and the chemistry and
.
radiochemistry sections. The RPM also has direct access to the Director,
Nuclear Operations. Within the RP section, there are four major groups:
radwaste, HP technical support, radiation work permits (RWP)/ALARA, and HP
operations. The radwaste section functions will remain similar to its
present arrangement with shipping, HP, and laundry subsections; HP
l
technical support section includes dosimetry, steam generator support, and
c
instrumentation / respiratory subsections; RWP/ALARA section includes-
,
specialists and technicians; and HP operations section includes shift
scheduling, decontamination, and two HP shift crews for each unit.
The HP
shift crews for each unit will be scheduled to work two 10-hour shifts
,
with a minimum of one HP available at each unit during the remaining
,
4-hour period in the day.
The licensee had increased staffing levels with both the permanent plant
i
staff and contractor support to improve performance in the RP area.
The
'
RPM has a total of 87 station employees and 36 contractor'HPs working
under his supervision in addition to clerical and control point personnel.
The station organization presently consists of 3 HP' superintendents over
HP operations, radwaste, and technical support groups;'10 HP supervisors;
2 HP specialists; 59 grade one HP technicians; and 13 junior.HP
technicians. At present, 13 of the 59 grade one HP technicians are in a
'
dedicated training program. Although some of the 13 technicians in
training could be qualified as ANSI 18.1-1971 senior technicians, they do
not meet AN0's qualifications criteria.
The station RP organization is supplemented by a contractor HP staff that
consists of 3 supervisors,16 senior' HP technicians, 6 decontamination
.i
technicians, 9 laundry personnel, and 2 respirator cleanirg and repair
'
employees.
The licensee's HP staff turnover was less than 10 percent during the past
year.
Vacancies, which existed mainly from expansion of the HP staff,
were filled by qualified individuals.
The' inspectors reviewed selected licensee's RP program operating
procedures.
Those procedures and other documents reviewed are listed in
the Attachment to this report.
The licensee had made extensive revisions
to upgrade their procedures during the past 2 years.
No violations or deviations were identified.
7.
External Radiation Exposure Control and Personal Dosimetry
The inspectors examined the licensee's external radiation exposure control
and personal dosimetry program to determine agreement with the commitments
in Chapters 12 and 13 of the Units 1 and 2 USARs and compliance with
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, 20.409, 50.72 and 50.73; and
Section 6 of the Units 1 and 2 TSs.
.
,
..
.
,
-7-
,
}
.
The inspectors reviewed selected aspects of the licensee's external
l
radiation exposure control and personal dosimetry programs. including:
'
changes .in facilities, equipment, personnel, and procedures; personnel
dosimetry program, required records, reports, and notifications; and
j
management effectiveness. Also reviewed were SRD issuance, use, and
!
calibration programs.
The licensee uses an in-house TLD program that is National Voluntary
j
Laboratory Accreditation Program accredited for ANSI-N13.11-1978
i
Categories I-VIII.
The program includes quarterly quality control test
3
evaluations by means of TLD badges spiked by an independent testing
!
laboratory. . The monthly personnel TLD results are compared with the
1
individual's recorded SRD results.
Anomalies between an individual's TLD
4
!
and SRD results are investigated.
The daily dose accountability / tracking program is part of-the Radiation
(
Exposure Monitoring System (REMS) which is a computerized information
i
system that allows the entry and retrieval of RP information.
Each pe'rson
I
who enters and exits the RCA is required to log their SRD readings into
'
the computer system. These readings are verifiea by a control point
clerk. The REMS appeared adequate to track authorized personal dose
limits.
I
The inspectors observed and discussed with licensee representatives
radiological-controls of, and access to, radiation, high radiation, and
very high radiation areas. The inspectors also reviewed selected RWPs and
.
associated radiation surveys and observed the instructions being given by
'
HP personnel to workers entering RCAs.
Overall, the licensee's practices
appeared to provide adequate radiological controls.
,
No violations or deviations were identified.
8.
Internal Radiation Exposure Control and Assessment
,
!
The licensee's program for internal radiation exposure control and
l
assessment was examined to determine compliance with the requirements of
10 CFR Part 20.103 and agreement with the recommendations of NRC
.;
Regulatory Guides (RGs) 8.15 and 8.26, NUREG-0041, NUREG-0938, ins 84-24
~
and 86-46, and ANSI N343-1978.
l
The inspectors reviewed the licensee's internal radiation exposure control
and assessment program including:
changes to procedures affecting
internal radiation exposure control and personal radiation exposure
)
assessment; determination whether engineering controls, respiratory
'
equipment, and assessment of incividual intakes meet regulatory
i
requirements; planning and preparation for maintenance and refueling tasks
'
including ALARA considerations; and required records, reports, and
,
notifications.
j
d
i
)
J
,
-
,
e .-
,
-8-
The program to control internal radiation exposures includes engineering
controls, airborne sampling and contamination control, and use of approved
respiratory devices and protective clothing. Whole body counting is used
to supplement the monitoring program to ensure its effectiveness.
The
engineering-contrels include use of portable ventilation units in selected
,
creas.
!
!
Air sample data were reviewed. Air samples were taken, counted, and
l
evaluated in accordance with established procedures. The procedures
j
appeared adequate for determining air sample results, placement, and type
i
of air sampling equipment.
Special air samples were collected to
!
establish RWP requirements and job cor.ditions, and it appeared that the
!
licensee adequately used air sample results to establish proper
i
requirements for the use of respirators and protective clothing.
,
!
The inspectors reviewed whole body counter (WBC) procedures and the WBC
i
facility and equipment. The inspectors also reviewed the licensee's WBC
i
calibration procedures and the results of the calibrations performed on
the WBCs. The sources used for instrument calibration were traceable to
"
the National Institute of Standards and Technology (NIST).
l
The inspectors also reviewed the WBC Procedure 1642.009, " Estimation of
1
Airborne Radioactivity Concentrations Using WBC.Results," and its method
j
of relating whole body counting data to regulatory limits (MPC-hours).
I
The inspectors requested the-licensee to use the procedure to' convert WBC
data to MPC-hours from an. example provided by the inspectors. The
inspector verified that the results of the licensee's conversion were
'
-
correct.
The inspectors noted the licensee's procedures did not address actions for
j
whole body counting of personnel who cleared beta-sensitive personnel
'
contamination monitors Model-1B (PCM-1Bs) but repeatedly alarmed
.
gamma-sensitive portal monitors Model-7 (PM-7s).
The inspectors noted
!
that such an occurrence might indicate internal contamination with gamma
.j
emitting radionuclides. This matter, along with the issues regarding RCA
exit controls and contamination release limits discussed in paragraphs 9.a
and 9.c, respectively, are considered an unresolved item pending further
NRC evaluation of the licensee's action concerning personnel alarming the
PM-7 monitors (313/9004-06; 368/9004-06).
Selected aspects of the licensee's respiratory protection program were-
i
'
reviewed. Workers' respiratory usage authorization information included
respirator qualification.
The qualification required a medical
evaluation, proof of training, and an expiration date.
The information
,
had been incorporated into REMS to ensure that only qualified workers
would be issued respirators.
Provisions were made during the issuance and
return cycle of respirators for MPC-hour accountability.
No unreturned
respirators were observed in the plant during inspection tours; however,
4
there was no specific mechanism which ensured that workers returned used
respirators before they were reissued a new respirator.
Observation of
the licensee's cleaning and maintenance area indicated sufficient
a
]
.
..
-9-
,
.
attention was being given to respirator inspection, storage, and
i
mainter,ance. The licensee appeared to have a satisfactory respiratory
protection program.
No violations or deviations were identified.
- 9.
Control of Radioactive Materials and Contamination, Surveys,
.
and Monitoring
L
The inspectors examined the licensee's program for the control of
.
7
radioactive materials and contamination, surveys, and monitoring to
- i
determine agreement with commitments conte.ined in the Units 1 and 2 USARs;
compliance with the requirements contained in 10 CFR Parts 19.12, 20.4,
20.5, 20.201, 20,203, 20.207, 20.301, 20.401, 20.402, and 30.41; and
'
'
agreement with the recommendations of RGs 7.3 and 8.25 and ins 80-22,
-
84-82,- 85-92, 86-23, 86-43, 86-44,86-107, and 87-39.
-
The inspectors reviewed the licensee's program for control of radioactive
materials and contamination including:
inventory, maintenance, and
calibration of survey and monitoring equipment; adequacy of review and
dissemination of survey data; and effectiveness of methods of control of-
radioactive and contaminated materials,
a.
Access Controls
The station's entrance and exit control points to the RCA are located
inside the auxiliary building.
Radiation protection
technicians (RPTs) are stationed where they can monitor the RCA
entrances and exits.
The RPTs are instructed to respond to alarming.
personnel contamination monitors (PCM-1Bs). Personnel are required
to use the automated PCM-1Bs located at the RCA exit control point
.
for whole body frisking and the portal monitors (PM-7sP) located at
the security exit.
The practice of RPTs maintaining the RCA entrance
and exit control stations strengthens the contamination control
program.
However, it was noted that RPTs were stationed at the RCA
exit control point only during normal working hours.
The licensee
was not providing full time HP coverage at the RCA exit control
'
point.
This practice weakened the contamination control. program.
The. inspectors noted that the potential existed for personnel to not
frisk properly or report alarms, and that contaminated equipment and
tools may be taken out of the RCA into clean areas.
This matter was
discussed with the licensee dur.ing the exit meeting on February 2,
1990, and is considered an unresolved item pending further NRC review
of the licensee's controls established at RCA exit points
(313/9004-06; 368/9004-06).
The inspectors reviewed the licensee's monitor alarm setpoint
methodology, functional tests, and calibration procedures for the RCA
,
L
exit PCM-1B monitors and station security exit PM-7 monitors. The
required tests and calibrations appeared to be performed in
accordance with approved procedures.
The PCM-1Bs were set to alarm
l
l
-
--
t
<
o{
,
a<
- ,
-10-
s
at a nominal 5000 disintegrations per minute (dpm)/100 square
centimeters (cm2) (2.5 nanocuries) and the PM-7s were set at about
,
200 nanocuries.
The inspectors indicated a more reasonable alarm
i
setpoint for the PM-7s would be 100 nanocuries in order.to increase
the likelihood of detecting possible contamination and hot particles.
3
b.
Equipment and Tool-Control
The inspectors reviewed the licensee's radiological cortrol program
I
for tools and equipment which were stored, distributed, and returned
to the contaminated (hot) tool crib. During the review of the
program, the inspectors interviewed a hot tool crib worker and HP
management personnel.
The inspectors also reviewed routine hot tool
crib radiation survey results and performed an independent radiation
survey of tools and equipment stored in the hot tool crib.
Although no violations were noted during this inspection, the
contaminated equipment and hot tool control program showed definite
weaknesses.
The inspectors noted that many tools had not been
returned to the hot tool crib.
Equipment and tools were stored in
various plant areas awaiting survey and/or. decontamination.
Licensee
personnel stated that activities during the recent outage were
suspended in order to collect tools / equipment'left scattered
throughout the containment building. The buildup of uncontrolled
potentially contaminated tools is a poor HP practice which weakens
4
the contamination control program.
It appeared that increased
management attention and worker training was.necessary to strengthen
the program. This matter was discussed with the licensee during the
exit meeting on February 2,1990, and is considered an open item
'
pending further NRC review of the licensee's housekeeping program for
contaminated equipment and hot tools (313/9004-07; 368-9004/07),
_
c.
Contamination Controls
Problems were noted with the licensee's HP Procedure 1622.017,
" Operation of a Control Point."
It specified a. numerical release
'
limit of 100 counts per minute (cpm)/100 cm2 above backgraund,
'
thereby, implying permission to release measured levels of'
radioactive contamination to an unrestricted area. The licensee was-
informed that NRC regulations do not permit disposal of licensed
radioactive material except as specified in 10 CFR 20.301.
The
inspectors also referred the licensee to IN 85-92, whicn provides
information in this area.
The use of this release limit may be partially responsible for
. occurrences of low-level contaminated tools, equipment, and trash at
the station.
This was evidenced by the requirement for hot tool crib
workers to wear cotton gloves, by contaminated soil / ash found at the
site landfill (paragraph 15), and by significant numbers of PCEs in
" clean" areas. The likelihood of such events was also increased by
the fact that contamination surveys were frequently performed using
r
- -
-
-
%
[
.
..
-11-
portable hand-held friskers in varying, and often times, elevated
radiation background areas.- During the time spent observing licensee
activities between January 29 - February 2,.1990, the inspectors did
c
not observe any specific instances where radioactive material was
released to the unrestricted area.
However, the statement in'
Procedure 1622.017 provides the possibility for low levels of.
I
'
contamination to be released.
These matters were discussed with the
.
licensee during the exit meeting on February 2, 1990.
The licensee
'
stated that HP Procedure 1622.017 would be. revised to reouire that
contamination above background levels would not be released to the
l
unrestricted area.. -This is considered an unresolved item pending -
further NRC review of the licensee's survey program.for release of
material to the unrestricted area (313/9004-06; 368/9004-06).
The inspectors reviewed selected PCE records.
PCE reports were
j
generated when radioactive contamination was detected on skin or
.I
clothing at levels greater than the 100 cpm above background.
The
licensee had significantly reduced PCEs from 2875(954 skin and
1921. clothing) in 1988 to 534 (222 skin and 312 clothing) in 1989.
Licensee initiatives included improved training, better oversight
during protective clothing removal, increased disciplinary actions
j
for repeat offenders, issuance of modesty garments to wear under
!
outer protective clothing, and more aggressive management
';
involvement.
However, the inspectors noted that further improvements
!
are still needed in this area since most of the 1989 PCEs occurred in
" clean" areas of the RCA.
4
General housekeeping was adequate, but housekeeping in t'ne hot tool
- j
decontamination room and hot machine shop was very poor. The
i
inspectors noted that housekeeping responsibility for these areas had
not been established in written procedures,
j
d.
Hot Particle Program
4
As part of the overall contamination control program, the licensee
l'
had developed a hot particle program which included specific guidance
to RPTs for controlling hot particles. This guidance addressed
particle detection, particle removal, quantification and analysis,
l
and the requirements for performing prejob evaluations and protective
,
measures for tasks with potential for hot particles. The licensee
!
identified 293 hot particles in 1989 (106 on individuals and 187 on
i
surfaces / components).
No personnel received radiation exposures in
excess of regulatory limits from hot particles,
s
q
l
The licensee was requested by the inspectors to compute skin dose for
some hypothetical hot particle incidents using different
!
V
\\
\\.
l
.
.;
.-
,
'
-12-
radionuclides at a skin density of 7 milligrams /cm2 (averaged
2
over 1 cm ).
Licensee and NRC calculations were in close agreement.
It appeared that the licensee's hot particle dose evaluation program
was adequate.
No violations or deviations were idantified.
10. Maintaining Occupational Radiation Exposures ALARA
The inspectors reviewed the licensee's program for maintaining
occupational-radiation exposures ALARA to d2termine agreement with the
commitments in the Units 1 and 2 USARs; con.pliance with the requirements
of 10 CFR Part 20.1(c); and agreement with the recommendations of RGs 3.8,
8.10, and 8.27, and IN 83-59, 84-61, 86-44,86-107,.and 87-39.
The licensee's ALARA program is well defined in Administrative
Procedure 1000.033 and Section 1612.000 of the plant's operating
procedures.
The HP group ALARA coordinator is responsible for site ALARA-
activities.
During normal plant operations, the coordinator is assisted
by two HP technicians. The ALARA program had received additional
management support during the last year. During the 1989 Unit 2 refueling
' outage, five additional ALARA coordinators and several technicians were
added to the RP staff, about I week after the outage started, to support
the ALARA group. These support personnel were assigned to specific work
groups such as design change, maintenance support, mechanical maintenance,
electrical maintenance, and engineering with the primary task to review
all jobs assigned to their group for ALARA considerations and identify
methods to reduce radiation exposures. Additional assignments included:
tracking exposures against goals; identifying and communicating to the
ALARA group and management problem areas they cannot resolve; tracking,
evaluating, and investigating PCEs; observing work in progress to ensure
,
ALARA techniques are being used and controling unnecessary personnel
'
exposures; assisting in mock-up training, prejob briefings, and postjob
reviews; and documenting exposure saving techniques used and quantifying
the dose saved.
The ALARA coordinator routinely performs evaluations.of
chronic problem areas' to reduce the radiological source term by flushing,
i
chemical decontamination, or engineering changes.
The actual radiation exposure,' based on licensee data, received during-
1989 versus the 1989 annual goal is summarized in Table 1 below. The
licensee had established the 1989 annual goal prior to managements
scheduling for the Unit 1 midcycie outage (1M89).
1M89 started on
November 27, 1989, and was completed on December 23, 1989, and had a goal
of 145 person-rem.
There was approximately 33 person-rem of additional
exposure received on work performed outside the original scope of the
goal.
IL '
l
9:
- 4
-13-
.
TABLE 1
Exposure (Person-Rem)
Activity
Goal
Actual
Normal Operations
111.721
142.715'
2R7
334.859-
282.171
Forced Outages
43.420
130.630
1M89
.
155.048
Totals
490.000
710.564
- Not includeo in 1989 annual goal
.
TABLE 2*
5 Year Exposure History
'
ANO vs pWR National Average
(in person-rem)
1985
1986
1987
1988
1989
143
571
-191
694
710
427
390
371
336
292
'
- Table 2 depicts the person-rem exposures at ANO fer the past
5 years.
It should be noted that the ANO exposures represent the
total person-rem for two units while the PWR national average is
based on a single unit.
The licensee has placed increased emphasis on ALARA and exposure reduction
in 1989. August 1989 was designated ALARA Awareness Month and resulted in
the lowest total monthly personnel exposure since May 1986.
The inspectors discussed with licensee representatives the access to the
Unit 1 emergency diesel generator (EDG) room. A NRC concern had been
discussed in the " Diagnostic Evaluation Team Report for Arkansas Nuclear
One," dated December 21, 1989.
The licensee had evaluated this NRC
concern and determined that the radiation level in the Unit 1 EDG room
-
resulted from an overhead drain line which measured 300 mrem /hr on
contact. The licensee flushed the drain line twice and reduced the
radiation level to approximately 20. mrem /hr on contact. The licensee was
evaluating the action to either redirect the line or install a filter to
reduce the radiation level in the drain line.
l
The ALARA group is working with the operations group to identify other
areas within the plant where a similar condition could exist.
They have
l'
planned to tour the plant with an operator to assess those areas where
operations personnel are required to tour and evaluate other radiation
L
l~
l
-
I
.
o
-14-
.
exposure areas which exist in addition to contaminated areas. Attention
will be directed toward other work groups upon completion of this task
until all work groups have been addressed.
The licensee had Durchased the " Surrogate Tour," a laser video disc
system, for Unit 1.
The Surrogate Tour uses the ccmbined technology of a
laser videedisk and personal computer to simulate motion and provide
detailed visol information of designated areas within the contaminated or
restricted area. This system will be used to assist the ALARA group in
all phases of the ALARA program from job preplanning, prejob briefing,
postjob reviews, maintenance training, to design analysis work.
A major ALARA area where improvement is needed is computer support.
The
ALARA group had incorporated a hot spot and temporary shielding computer
tracking system and were maintaining good control of these areas, but the
job history files were incomplete.
The inspectors discussed other
programs that could be incorporated into the ANO computer system which
would provide useful data to the ALARA group, such as on-line RWP exposure
updates, RWP sign-in, and ALARA prejob briefing clearance.
The inspectors
discussed with the licensee during the exit meeting the possibility of
providing ALARA personnel the opoortunity to visit other nucirar power
facilities to observe where additional improvements could be made to the
overall ALARA program.
No violations or deviations were identified.
11.
Personal Contamination Events (PCE)
The inspectors reviewed the circumstances related to a PCE which occurred
on December 19, 1989. The inspectors reviewed RP records and the
licensee's investigation documentation of the incident and discussed the
matter with licensee representatives.
On December 19, 1989, a waste control operator was cuntaminated with
primary system water as the result of a valve line up problem. He alarmed
the PCM-1B whole body monitor upon exiting the RCA. Subsequent hand-held
frisker surveys identified contamination on his hands, face, and the back
of his neck (hair). After several decontamination $ had been performed,
the individual passed the PCM-18, and a hand-held frisk, and then left the-
site. A whole body count (face up) was performed the following day
(December 20,1989) which indicated contamination levels of 30 nanocuries
of cobalt-58 in the upper body region.
Subsequent surveys narrowed the
contamination to hair located on the side and back of his head.
The
individual was still able to clear the PCM-1B monitor on that day. A
subsequent ( uit) whole body count performed on January 16, 1990, showed
about 8 nanocuries of cobalt-58.
On January:19, 1990, the licensee received a call from the Waterford-3
Steam Electric Station informing them that the same individual had alarmed
their PCM-1B monitor while exiting their RCA.
The alarms were for the
head area. Af ter being informed of the contamination event, AP&L directed
_
E
!
'
,
.
0
-15-
i
.
the worker to return to ANO.
The licensee (ANO) was aware that the worker
was contaminated because of the results of the January 16, 1990, whole
body count.
However, ANO personnel did not inform the Waterford-3 RP
staff because the individual's planned visit to Waterford-3 was unknown to
the persons performing the whole body count.
The individual returned to ANO on January 20, 1990, and an investigation
was initiated. Whole body counts were performed face-up and face-down,
which indicated about 6 nanocuries and about 19 nanocuries (cobalt-58),
respectively. Again, monitoring with a hand-held frisker indicated net
activity below 100 cpm.
The investigation included an assessment of bocy
dose but not skin dose because the contamination was dispersed in the
individual's hair.
The licensee's investigation revealed that between December 20, 1989, and
Janua ry 16, 1990, the individual recalled that he frequently (about half
the time) alarmed the PCM-1B monitors at the exit of the RCA which he
i
reported to the RCA exit control technician who then surveyed him with a
hand-held frisker and found no measurable contamination above 100 cpm.
'
During backshift, when the RPTs were not attending the RCA exit control
point, he frisked himself with the same negative results.
Licensee HP
personnel stated they were unaware of the recurring monitor alarms during
this period. An alarm rate of aoout 50 percent on two PCM-1Bs was also
found when the individual was monitored as part of the licensee's
investigation. The PCM-1Bs were nominally set to alarm at 2.5 nanocuries,
the same level as at Waterford-3.
There are known areas (dead spots)
wriere the sensitivity is not quite up to the manufacturers or licensee's
desired minimum detectable level.
Head positioning could account for a
higher level of activity not being detected 100 percent of the time. The
individual stated that he had informed a training instructor, who reviewed
the PCM-1B printouts, of the repetitive alarms.
The training instructor
indicated the contamination was low level and no cause for concern. HP
was not notified.
I
The licensee's investigation identified no procedural violations and no
l
personnel errors, but did identify the need to track repetitive monitor
4
alarms.
However, the inspector's review of this matter identified the following
problems:
a.
A whole body count was not performed immediately after the facial
contamination was identified. The licensee's procedures stated that
a whole body count should be performed if contamination is
identified, but the procedures did not specify a specific time for
conducting such analysis. However, the individual was instructed to
submit to a whole body count the following morning (December 20,
1989).
The results of the whole body count identified about
34 nanocuries of cobalt-58 on the back of his head.
!
l
l
l
t
!
t
.
.
-16-
b.
Failure to follow the requirements for decontamination of hair
contamination in Procedure 1622.010 - Attachment II, which states
that hair which cannot be decontaminated be removed. The worker's
hair was identified as contaminated by the PCM-1B monitor on
December 19, 1989, and by a whole body count on December 20, 1989.
Failure to remove the individual's contaminated hair appeared to be a
violation of the licensee's procedure,
c.
Failure to have ft11 time HP coverage at the RCA exit control point
is a weakness, as discussed in paragraph 9.a.
TS 6.1.8.a for Units 1 and 2 requires that written procedures shall be
established, implemented, and maintained covering activities recommended
in Appendix A of Regulatory Guide 1.33.
Section 7.e addresses
contamination control.
Paragraph 6.4.2 of the licensee's Procedure 1622.010. " Personnel
Decontamination," Revision 15, dated November 17, 1989, states that
decontamination of an individual is to be initiated " utilizing the
guidelines provided in Appendix II," and Attachment II directs the person
to " remove any hair that cannot be decontaminated."
The failure to remove the contaminated hair from the individual found to
have 30 nanocuries of cobalt 58 in his hair on December 20, 1989, is
considered an apparent violation of TS 6.1.8.a for both units
(313/9004-01; 368/9004-01).
No deviations were identified.
12.
Liquids and Liquid Wastes
The inspectors reviewed the licensee's liquid radioactive waste effluent
program including:
liquid waste processing, liquid waste sampling and
analysis, procedures for control and release of radioactive itquid waste
effluents, and reactor coolant and secondary water quality to determine
agreement with commitments in Chapter 11 of the Units 1 and 2 USARs and
compliance with the requirements in Sections 3.25.1, 4.29.1, and 6.14 of
the Unit 1 TS and Sections 3/4.11.1, and 6.14 of the Unit 2 TS and the
,
Offsite Dose Calculation Manual (00CM).
!
The inspectors reviewed the licensee's implementation of the Radiological
Effluent Technical Specifications (RETS) and ODCM to ensure agreement with
'
analysis sensitivities, reporting limits, analytical results, sampling
requirements, surveillance tests, radioactive waste effluent
l
program (RWEP) operating procedures, offsite dose results from liquid
i
effluents, and functional checks and calibrations of equipment associated
,
'
with the RWEP.
l
The inspectors reviewed current approved revisions of ANO procedures
I
governing the release of liquid radioactive waste.
These liquid effluent
release procedures provided for the following:
sampling of radioactive
!
l
.
.
.
-17-
.
liquid waste; chemical and radionuclide analyses prior to release;
,
calculation of effluent release rates, effluent radiation monitor
setpoints, projected offsite radionuclide concentrations, and projected
offsite doses prior to release; recording effluent dilution parameters and
verifying effluent discharge flow rates and effluent volume discharged
during the release; and the calculation of actual offsite radionuclide
concentrations and offsite doses after the completion of the release.
The inspectors reviewed a representative number of batch liquid effluent
release permits for the period January 1989 through December 1989.
It was
determined that processing, sampling and analysis, and approval and
,
performance of the liquid effluent releases were conducted in accordance
with ANO procedures.
Quantities of radionuclides released in the liquid
effluents were within the limits specified in the RETS. Offsite doses had
been calculated according to the ODCM and were within the TS limits.
Liquid effluent radiation monitor setpoints were calculated and set in
accordance with the ODCM and ANO procedures.
The inspectors noted that in 1988 and 1989, the licensee had incorporated
a Duratek Enhanced Volume Reduction Processing System into the liquid
radwaste processing systems in both Units 1 and 2.
This system bypasses
i
the original liquid radwaste demineralizers installed for liquid radwaste
processing. The inspectors verified that changes made to the liquid waste
system received the proper 10 CFR 50.59 approval.
The inspectors reviewed selected reactor coolant and secondary water
chemistry records for the period January through December 1989.
The
records reviewed indicated that all required sampling and analyses were
performed at the frequencies required by the TS.
The chemical parameters
were controlled within TS limits and did not produce excessive amounts of
chemicals and radionuclides in the liquid radwaste which would cause
elevated liquid effluent concentrations of chemicals and radionuclides to
be released to the environment.
The inspectors reviewed the licensee's June 27, 1989, response to
Condition Report 1-88-0321.
In the original condition report, dated
'
October 11, 1988, the licensee described the facts surrounding the
'
transfer of radioactive contaminated liquid waste from the ANO sanitary
sewage treatment facility to the Russellville Municipal Sewage Treatment
System. On Friday, October 7, 1988, 6000 gallons of liquid waste were
transported from the ANO sewage treatment facility aeration tank to the
Russellville Municipal Sewage Treatment System for further processing and
disposal.
Prior to the transfer of the sanitary liquid waste on
October 7, 1988, samples were taken from all three sandbeds, two dosing
tanks, and the aeration tank. The analyses of these samples were
completed in the afternoon, but af ter the sanitary liquid waste from the
aeration tank had already been transferred. All of the samples taken on
October 7, 1988, except for the west dosing tank, indicated levels of
cesium-137 (<1.0E-6 pCi/cc). These radioactive concentrations are
slightly above the lower limits of detection for the counting instrument
used to analyze the samples.
Routine monthly samples and analyses of
-
-
-
-
,
,
C-
4
-18-
,
,
liquid waste transported to the Russellville Municipal Sewage Treatment
System prior to October 7, 1988, had not indicated any measurable
radioactivity.
The positive results of the sample analyses performed on
October 7, 1988, were not made known to chemistry supervision until
Tuesday, October 11, 1988, at which time Condition Report 1-88-0321 was
written. The inspectors reviewed the results of the chemistry group's
sampling and analyses of the ANO sewage treatment facility samples during
the period January 1 through December 31, 1989, and found no indication of
detectable radioactivity.
10 CFR 20.301 requires that no licensee shall
dispose of licensed material except by transfer to an authorized recipient
>
or by obtaining approval pursuant to 10 CFR 20.302.
NRC IN 88-22
" Disposal of Sludge From Onsite Sewage Treatment Facilities at Nuclear
Power Stations"'also discusses NRC requirements regarding contaminated
sewage. The disposal of radioactive contaminated sewage in the
Russellville Municipal Sewage Treatment System is an apparent violation of
10 CFR 20.301 (313/9004-04; 369/9004-04).
The inspectors reviewed the response to Condition Report 1-88-0321 and
determined that the licensee had implemented the following corrective
actions:
Increased surveillance sampling from monthly to weekly.
Installed an automatic sempling system on the aeration tank to
provide a daily composite sample.
Performed sampling once per shift when automatic sampler failed.
Sampled and analyzed samples of aeration tank prior to loading and
release of each load to the Russellville Municipal Sewage System.
.
The licensee's corrective actions were reviewed by the inspectors on
January 31, 1990, and determined to be adequate to correct the
licensee-identified violation and prevent a recurrence.
No deviations were identified.
13.
Gaseous Waste
The inspectors reviewed the licensee's gaseous radioactive waste effluent
program including:
gaseous waste processing, gaseous waste sampling and
analysis, procedures for control and release of radioactive gaseous waste
effluents, and air cleaning systems to determine agreement with
commitments in Chapter 11 of the Units 1 and 2 USARs and compliance with
the requirements in Sections 3.9, 3.13, 3.15, 3.22, 3.25.2, 4.10, 4.11,
4.17, 4.25, 4.29.2, and 6.14 of the Unit 1 TS and Sections 3/4.7.6,
3/4.9.4, 3/4.9.11, 3/4.11.2, and 6.14 of the Unit 2 TS and the ODCM.
The inspectors reviewed the licensee's implementation of the RETS and ODCM
,
to ensure agreement with analysis sensitivities, reporting limits,
j
analytical results, sampling requirements, surveillance tests, RWEP
1
.
.
.
.
-19-
.
operating procedures, offsite dose results from gaseous effluents, and
functional checks and calibrations of equipment associated with the
radioactive gaseous waste processing systems.
The inspectors reviewed current approved revisions of ANO procedures
governing the release of gaseous radioactive waste. These gaseous
effluent release procedures provided for:
sampling of gaseous radioactive
waste, calculation of projected offsite gaseous radionuclide
concentrations and doses, calculation and verification of gaseous effluent
radiation monitor setpoints, and verification of discharge flow rate and
effluent volume discharged.
The inspectors reviewed the licensee's radioactive gaseous waste program
to determine compliance with the requirements of TS 4.29.2.1 and
Table 4.29-3 in the Unit 1 TS and the requirements of TS 3/4.11.2.1 and
'
Table 4.11-2 in the Unit 2 TS.
Selected gaseous waste release permits
which included unit vent continuous releases and batch releases from waste
gas decay tanks and containment from both Units 1 and 2 for the period
January through December 1989 were reviewed.
It was determined that the
sampling and analyses of the gaseous effluents and the approval of the
gaseous releases were conducted in accordance with ANO procedures.
.
Quantites of gaseous radionuclides released were within the limits
specified in the RETS. Offsite doses had been calculated according to the
ODCM and were within the TS limits.
Chapter 11, paragraph 11.1.3.6.2 of the Unit 1 USAR and Chapter 11,
'
paragraph 11.3.6.11.1 of the Unit 2 USAR describe the gaseous radioactive
waste systems of the respective units.
These paragraphs state, in part,
that the waste gas systems provide storage for radioactive gases in waste
gas decay tanks designed to hold radioactive waste gas for decay of the
gaseous radionuclides prior to release to the environment. The waste gas
is to be compressed to a nominal isolation pressure of approximately
123 psig and stored in the waste gas decay tanks until the radioactivity
level drops sufficiently to be discharged through the discharge header to
the environment.
The decay tanks in each unit are conservatively sized to
provide a total gas storage capacity to process all the waste gas
generated in a postulated operating cycle assuming a 30-day decay period
for the waste gas held in the tanks and a 15-day release period.
On February 1,1990, the inspectors reviewed the waste gas decay tank data
associated with the two gas decay tank releases performed from Unit I and
-the seven gas decay tank releases performed from Unit 2 during 1989 and
determined that the gaseous radioactive waste systems installed in both
units were not being operated per the USAR design criteria.
Five of the
nine total waste gas decay tank releases performed from both units in 1989
were started with an initial isolation tank pressure in the gas decay tank
'
not exceeding 100 psig.
This method of operation is a waste of gas decay
tank capacity and is in deviation from the USAR operational design
criteria. Also, only three of the nine gas decay tanks released in 1989
were released after being isolated for 30 days or longer to allow for
adequate decay of the xenon radionuclides prior to release to the
!
..
,
.
-20-
.
environment.
Four of the six gas decay tanks which were released prior to
a 30-day or longer decay time were isolated and held for decay for less
than 10 days and two of these tanks were isolated and decayed for less
than 1 day. This practice allowed the release of radioactive gases to the
environment at concentrations much higher than would have been released if
the radioactive gases had been isolated and allowed to decay for 30 days
or longer.
It was observed that waste gas released during the four gas
decay releases which were made in less than a 10-day decay time had
concentrations of xenon-133 as high as 4.0E-01 microcuries per cubic
centimeter. This method of operation of the waste gas decay system by not
isolating radioactive waste gas for decay for 30 days or longer is a
deviation from the USAR operational criteria of the waste gas processing
system. The inspectors also noted that six gas decay tank releases from
,
Unit 2 in January 1990 were performed prior to a 30-day or longer
'
isolation decay time.
These six Unit 2 gas decay tank releases were made
in preparation for isolation of the Unit 2 waste gas system prior to the
-
10 year inservice inspection hydrotest of the system. The operation of
the waste gas processing system not utilizing the total volume of waste
gas capacity for storage and decay and not allowing radioactive waste
gases to be isolated and stored for decay for 30 days or longer prior to
release to the environment is considered a deviation from Chapter 11,
paragraph 11.1.3.6.2 of the Unit 1 USAR and Chapter 11,
paragraph 11.3.6.11.1 of the Unit 2 USAR (313/9004-05; 368/9004-05).
The inspectors reviewed the licensee's procedures, surveillance tests, and
selected records and test results for maintenance and testing of air
cleaning systems which contain high efficiency particulate air (HEPA)
filters and activated charcoal adsorbers.
The inspectors verified that
the licensee's procedures and surveillance tests provided for the required
periodic functional checking of ventilation system components, evaluation
of HEPA filters and activated charcoal adsorbers, and replacement and
in place filter testing of the various filter systems.
The inspectors
reviewed selected records and test results for the period January 1989
through December 1989 for the Unit 1 penetration room ventilation system,
fuel handling area ventilation system, reactor building purge-filtration
system, and control room emergency air conditioning and isolation system
and the Unit 2 fuel handling area ventilation system, containment building
purge and exhaust system, and control room emergency air conditioning and
air filtration system.
The in place filter testing and activated charcoal
laborar.ory tests had been performed by a contractor using approved
procedures. All test results were verified to be within TS limits.
The
licenste had performed a QA audit on the contractor performing the testing
on the station ventilation systems and had placed the contractor on the
l-
AND qualified vendor list.
No violations were identified.
l
l
l
l
.
.
~21~
4
14.
Radiation Monitoring Instrumentation
The inspectors reviewed the licensee's process radiation monitoring
instrumentation program to determine compliance with the requirements in
Sections 3.5.6, 3.5.7, 4.29.1.3, and 4.29.2.3 of the Unit 1 TS and
Sections 3/4.3.3, 3/4.3.3.9, and 3/4.3.3.10 of the Unit 2 TS.
The inspectors reviewed channel checks, source checks, channel functional
tests, and channel calibration procedures and records for area and process
radiation monitoring instrumentation which showed that the frequency of
radiation monitor checks, tests, and calibrations were being performed at
the required frequency using radioactive standards traceable to the NIST.
The inspectors reviewed two LERs which identified problems associated with
the operation and performance checks of the radiation monitoring
instrumentation.
In LER 368/89-021, dated December 11, 1989, the licensee identified to the
NRC the facts surrounding, and the subsequent evaluation of the release of
radioactive liquid effluent through a discharge flowpath which was
unmonitored during the release duration.
Unit 2 TS 3.3.3.10 requires that
a radiation monitor in a liquid effluent pathway be operable anytime
releases are in progress via that pathway.
On November 10, 1989, a waste
condensate tank, which contained low level radioactive waste water, was
aligned for release. A radiation monitor is located in the discharge
flowpath to provide a signal to close a control valve and terminate the
release in the unlikely event a high level of radioactivity is sensed by
the monitor at any time during the release.
In accordance with procedure,
a Unit 2 control room senior reactor operator coordinated with a waste
control operator to align the tank discharge flowpath and test the
radiation monitor. Upon completion of the waste condensate tank
discharge, it was recognized that the radiation monitor, which had been
tested prior to the release, had not been returned to operable status and
had not been operable for the duration of the release.
Prior to releasing the waste condensate tank, the monitor located in the
discharge line was verified by procedure to be operable by performing a
source check and ensuring the control valve in the discharge line closed
upon sensing high radiation by simulating a high radiation condition.
In
order to determine operability of the radiation monitor, a multipurpose
switch is placed in various positions to test and verify that the
radiation monitor responds as desired.
The radiation monitor is operable
i
only when the selector switch is placed in the operate position.
The
i
procedure used to perform the radiation monitor operability test required
the operator to initial the step verifying that the switch had been
returned to the operate position.
The procedure step had been initialed
as being completed without actually being performed.
The multipurpose
switch was left in the reset position making the radiation monitor
The licensee determined the root cause of this event was
personnel error.
!
^
,
<
.
.
[
-22-
.
The curie content of the liquid in the waste condensate tank wts analyzed
prior to releasing the contents of the tank and the quarterly and annual
wnole body and organ doses established by TS were not exceeded.
Therefore, the radiological doses, as a result of this unmonitored liquid
release, did not pose any significant radiological concarns. The licensee
determined that there had been no prevtously reported events regarding
unmonitored liquid radioactive releases.
As a result of this event, the licensee took the following corrective
actions:
The event was discussed with the senior reactor operator responsible
for verifying the multipurpose switch position and the necessity to
improve attention to detail and strict procedural compliance when
performing the operability verification of the radiation monitor.
The liquid release permit procedure was revised to ensure the
multipurpose selector switch for the radiation monitor being tested
is left in the operate position prior to initiating a waste liquid
release by the performance of an independent verification.
During operations training for Unit 2 operators, the Unit 2 plant
manager provided a review of this event and previous operational
events in an attempt to improve overall attention to procedural
detail.
The licensee's corrective actions were reviewed by the inspectors on
!
January 31, 1990, and determined to be adequate to correct the
f
self-identified violation and prevent a recurrence.
This matter would
normally be considered a violation of Unit 2 TS 3.3.3.10 requirements.
However, the NRC Enforcement Policy, 10 CFR Part 2, Appendix C (1989),
states that a Notice of Violation will generally not be issued for
violations identified by the licensee, if:
(1) it was identified by the
licensee; (2) it fits in Severity Level IV or V; (3) it was reported, if
required; (4) it was or will be corrected; and (5) it was not a violation
that could reasonably be expected to have been prevented by the licensce's
corrective actions for a previous violation.
This violation meets the
criteria specified in 10 CFR Part 2, Appendix C (1989), and is considered
a licensee identified violation and no Notice of Violation will be issued
concerning this matter in this report.
In LER 313/89-032, dated October 6, 1989, the licensee identified to the
NRC the facts causing the monthly functional test for the reactor building
area radiation monitors not to be performed as required by 15.
Unit 1
TS 4.1.a states that the minimum frequency and type of surveillance
testing required for the reactor protection system and engineered
safeguards system instrumentation when the reactor is critical shall be as
stated in Table 4.1-1.
Table 4.1-1 requires a monthly functional test of
the reactor building area radiation monitoring system.
On September 6,
i
}
.
,
.
e
,
~23~
1
.
1989, the licensee discovered that the required monthly functional test of
1
four area radiation monitors located in the Unit I reactor building had
not been performed within the allowable surveillance time interval
specified in the Unit 1 TS. A new procedure for the monthly testing of
all the area radiation monitors in the reactor building had been written,
and these monitors were deleted from the original test procedure which
retained the testing for the remaining Unit I area radiation monitors.
The two area radiation monitor testing procedures were approved and
1
implemented on June 26. 1989.
The MTCL, which lists the surveillances that are required by TS, is used
to ensure surveillances are scheduled and performed within the required
time intervals as established by TS.
When the new procedure was written
for the testing of the reactor building area radiation monitors and the
original procedure was revised to delete these monitors, a MTCL revision
,
was prepared and submitted for approval at the same tim' the new
procedures for testing the monitors were submitted for approval. After
review of the procedures and MTCL revision, the MTCL revision was found to
be unacceptable and was returned to the preparer to correct prior to
approval.
However, the testing procedures were approved and issued. On
.
September 6, 1989, the MTCL revision was approved. As a result, between
June 26, 1989, and September 6, 1989, the reactor building area radiation
monitors were not functionally tested monthly, since the MTCL did not
'
reference the new testing procedure.
This error was not detected because
the original procedure, which had contained the testing requirements for
the area radiation monitors located inside the reactor building, was
'
listed on the MTCL and had been properly scheduled and performed.
It
,
appeared that the reactor building area radiation monitors were being
tested as required by TS.
The station administrative procedure which provided guidance to personnel
concerning the procedure review, approval, and revision process did not
address the need to update the MTCL when a procedure, which may effect the
>
MTCL, is revised. The lack of procedural guidance to update the HTCL when
revising TS surveillance related procedures resulted in an unreliable
means of ensuring the MTCL was properly updated and correct.
The licensee
determined that there had been no previously identified similar events
which resulted in a TS surveillance not being performed within the
required testing interval because the MTCL was not properly updated.
As a result of this event, the licensee took the following corrective
actions:
On September 6, 1989, when it was discovered that the reactor
building area radiation monitor had not been functionally tested, the
monitors were declared inoperable until the testing requirements were
completed.
The monitors were tested satisfactorily and returned to
service on September 6, 1989.
\\
'
)
.
.
-24-
.
A change to the procedure revision request form, which is required to
accompany each procedure that is submitted for approval, was
submitted.
A specific entry on the procedure request form is
required to be completed for each procedure as to whether a change to
the MTCL is necessary or not.
If a change to the MTCL is required
for a given procedure, the required effective date for the procedure
to be implemented will be assigned when the MTCL is updated.
The licensee's corrective actions were reviewed by the inspectors on
January 31, 1990. The procedural guidance to ensure the updating of the
MTCL was inecrporated into Procedure 1000.006, " Procedure Review,
i
Approval, and Revision Control," Revision 30, Section 6.8 and approved on
November 17, 1989, with an effective dated of November 21, 1989.
This
matter would normally be considered a violation of Unit 1 TS 4.1.a and
Table 4.1-1 requirements.
However, the NRC Enforcement Policy, 10 CFR Part 2, Appendix C (1989), states that a Notice.of Violation will
generally not be issued for violations identified by the licensee, if:
(1) it was identified by the licensee; (2) it fits in Severity Level IV or
V; (3) it was reported, if required; (4) it was or will be corrected; and
(5) it was not a violation that could be reasonably be expected to have
'
been prevented by the licensee's corrective actions for a previous
violation. This violation meets the criteria specified in 10 CFR Part 2,
Appendix C (1989), and is considered a licensee identified violation and
no Notice of Violation will be issued concerning this matter.
Effluent Monitors
Unit 2 TS 4.3.3.9 states that each radioactive gaseous effluent monitoring
instrumentation channel shall be demonstrated operable by performance of
the channel check, source check, channel calibration, and channel
functional test at the frequencies shown in Table 4.3-12.
Table 4.3-12
requires the gas activity monitors in the Unit 2 spent fuel area
ventilation system, auxiliary building area ventilation system, and
auxiliary building extension ventilation system to be source checked
monthly.
Contrary to the above, the inspectors determined on January 30, 1990, that
the monthly source checks of the General Electric (GE) gas activity
radiation monitors in the Unit 2 spent fuel area ventilation
system (2RE-8540), auxiliary building area ventilation system (2kE-8542),
and auxiliary building extension ventilation system (2RE-7828) were last
tested on a monthly frequency on February 2, 1989, in accordance with
Procedure 2304.016 " Process Radiation Monitor System Test," Revision 9.
A new procedure (1104.021) for the monthly source testing of these
monitors had been written and the GE monitors had been deleted from the
original test pro edure.
The MTCL, which schedules and tracks the testing
requirements associated with TS, was not revised to include the new test
procedure. Therefore, the testing of the Unit 2 ventilation systems' GE
gas activity monitors was not schedcled.
<
F-
,
.
.
-25-
i
In March 1989, a procedure (2304.016) which contained the testing
requirements for all process radiation monitors located throughout Unit 2
was revised into two procedures, a new. procedure (1104.021) for monthly
source check testing of the GE process radiation monitors located in
!
Unit 2 requiring a monthly source check and a quarterly channel functional
test and the revised original procedure (2304.016) for the monthly source
check testing of the remaining process radiation monitors.
The two
procedures were approved and authorized for use.
However, the MTCL was
not revised to schedule the monthly testing of the GE monitors using the
l
new Procedure 1104.021. The GE process radiation monitors deleted from
i
the original procedure (2304.016) were channel functional tested quarterly
using Procedure 2304.173.
The three Unit 2 ventilation systems' GE gas
>
activity monitors were source checked on June 28, 1989, and September 8,
1989, as part of the performance of Procedure 2304.173 during the
quarterly channel function test on the monitors. The inspectors concluded
that the monthly source check of the Unit 2 ventilation systems' GE
radiation monitors had not been performed for the period March 1989
through January 1990 except for the 2 months of June and September when
the quarterly channel function test had been performed.
The failure to
perform the monthly source checks on the GE gas activity radiation
monitors in the Unit 2 spent fuel pool area ventilation system (2RE-8540),
auxiliary building area ventilation system (2RE-8542), and auxiliary
building extension ventilation system (2RE-7828) is an apparent violation
of Unit 2 TS 4.3.3.9 and Table 4.3-12.
(368/9004-02)
The inspectors noted that the above violation, as a result of the licensee
not updating the MTCL when revising a procedure which affects TS
{
requirements, is very similar to the event described in LER 89-032. This
t
would indicate, that when the licensee performed their investigation in
!
October 1989 to determine the root cause of the circumstances leading to
the event described in LER 89-032, they did not discover other cases where
procedure changes affecting TS required surveillances may not have been
updated on the MTCL.
During the inspection of the radioactive effluent monitoring
instrumentation surveillance requirements, the inspectors noted that the
[
licensee had installed a state-of-the-art radiation monitoring system in
l
both Units 1 and 2 in addition to the original GE radiation monitoring
syctem. These super particulate-iodine-noble gas (SPING) process
radiation monitoring systems had been tested in accordance with ANO
l
Units 1 and 2 procedures and had met TS testing requirements.
However,
'
there appeared to be some confusion on the part of the licensee as to
which radiation monitoring system (GE or SPING) was the official system to
be used to satisfy TS monitoring requirements. Therefore, since both
monitoring' systems were installed and operating simultaneously, it was the
j
inspectors understanding that both radiation monitoring systems must be
tested in accordance with TS requirements until the official TS monitors
are specifically designated by monitor identification number in the TS.
l
i
No deviations were identified,
i
_
-
.
,
-26-
.
15. Transportation Activities
The inspectors reviewed the licensee's radioactive material transportation
program to determine agreement with the recommendations contained in NRC
Bulletin 79-19, ins 79-21, 80-32, 83-10, 84-14, 84-50, 85-46, and 87-31;
and compliance with the requirements of 10 CFR Parts 20, 30, and 71 and
49 CFR Parts 171 through 189.
ihe inspectors reviewed select records of radioactive material shipments
made during 1989. Although the licensee routinely used an extensive
checkoff list for shipments of radioactive materials, which includes a
line for verification that a current copy of the transferee's license is
on file at ANO and had been checked off on the checklist,
Shipment RSR 69-89 (a single container of 108 cubic feet, weighing
approximately 1000 pounds and containing 0.05 mil 11 curies of the
radioisotopes (byproduct material) cobalt-56 and -60, cesium ~134
and -137, iron-55, and nickel-63 as metal oxides on equipment)'was shipped
on September 9, 1989, to a vendor. The byproduct material license in the
possession of the licensee for this sandor had an expiration date of
October 31, 1988.
10 CFR Part 30.41(c), Transfer of Byproduct Materials, states that before
transferring byproduct material to a specific licensee, the licensee
transferring the material shall verify that the transferee's license
authorizes the receipt of the type, form, and quantity of byproduct
material to be transferred.
Paragraph (d) of 10 CFR 20.41 lists those
methods that are acceptable for the verification required in paragraph (c)
i
such as the transferor having in his possession, a current copy of the
transferee's specific license or registration certificate.
,
Transferring byproduct material to a specific licensee without verifying
that the transferee's license authorized receipt of the material is
considered an apparent violation of 10 CFR Part 30.41(c) (313/9004-03;
368/9004-03).
The inspectors reviewed Condition Report CR-C-89-103 written by the
licensee on October 22, 1989, which identified the presence of radioactive
material in two areas of the licensee's landfill area. The landfill area
is located on the licensee's property with unrestricted access.
The
licensee had discovered and removed from the landfill a piece of steel and
approximately 110 cubic feet of dirt.
This volume was later reduced to
about 5 cubic feet of dirt and ash mixture.
Two areas in the landfill
indicated a radiation level of 250 to 300 cpm above background. The
indicated radiation level of 300 cpm would correspond to a gamma dose rate
of 0.08 mrem /hr. The licensee theorized that several factors may have led
,
to the incident, but that the main cause was that waste thought to be
'
clean waste actually contained low-levels of radioactivity and was taken
to the incinerator, burned, and concentrated in the ash.
10 CFR 20.301 states, in part, that no licensee shall dispose of licensed
material except by transfer to an authorized recipient,
i
p
1
e
.
.
-27-
.
The dispost's of licensed material to the licensee's landfill area is
considered an apparent violation of 10 CFR 20.301 (313/9004-04;
368/9004-04).
The inspector reviewed the response to Condition Report C-89-103 and
determined that the licensee had implemented the following corrective
actions:
Temporarily stopped their radioactive waste segregation program.
Condveted training for personnel responsible to release clean
traterial s.
Improvements were made in the survey program.
Potentially clean
tras5 was being frisked piece by piece and then monitored again using
a very sensitive gamma monitor after being bagged.
Trash with any
detectable activity is not permitted to be released for normal onsite
disposal of clean trash.
The licensee's corrective actions were reviewed by the inspectors on
Jtnuary 31, 1990, and determined to be adequate to correct the
self-identified violation end prevent a recurrence.
Although the presence of radioactive material in the landfill raised
concerns in other areas, the inspectors did not identify any violations of
,
10 CFR 2C.201, " Surveys" or 10 CFR 20.305, " Treatment or Disposal by
Incineration." This situation could have involved radioactivity that was
present in materials, but just below the detection limits of the survey
meter anc , therefore, released as clean material.
However, if the
material with less than detectable levels was allowed to accumulate and
concentrate over a period of time, such as ash in an incinerator, the
radiation levels could build up to be above background levels.
The
unresolved item discussed in paragraph 9.c could also contribute to this
problem area.
No deviations were identified.
16.
Reports of Radioactive Effluents
l
.
The inspectors reviewed the licensee's reports concerning radwaste systems
1
and. effluent releases to determine compliance with the requirements of
.
10 CFR Part 50.36(a)(2) and Section 6.12.2.6 of the Unit 1 TS and
l
Section 6.9.3 of the Unit 2 TS.
l
The ir.spectors reviewed the semiannual effluent release report for the
period January 1 through June 30, 1989.
The report was written in the
format described in RG 1.21, Revision 0, Appendix A, and contained the
information required by the Units 1 and 2 TSs.
Ne violations or deviations were identified.
1
!
,
m
. .
.,
~28-
,
17. 0A Program
The inspectors reviewed the QA surveillance and audit programs regarding
RP, radiological effluents, and radioactive waste transportation
activities to determine agreement with commitments in Chapter 17 of the
Units 1 and 2 USARs and compliance with the requirements in
Section 6.5.2.8 of the Units 1 and 2 TSs.
The inspectors reviewed the licensee's QA audit and surveillance schedules
for 1988, 1989, and 1990, selected QA procedures, surveillance and audit
reports, and the qualifications of the QA auditors and technical
specialists. Audit and surveillance reports generated from QA activities
during the period January 1988 through December 1989 in the areas of RP
and radwaste activities were reviewed for scope to ensure thoroughness of
program evaluation and to determine the timely followup of identified
deficie1cies. The surveillances, audit plans, and checklists were
comprehansive and performance based to ensure that plant activities were
in compliance with the USARs, TSs, and ANO procedures. All audit finding
reports and surveillance finding reports had been closed.
The inspectors
verified that the QA surveillances and audits had been performed in
accordance with ANO QA procedures and schedules and by qualified auditors
and technical specialists who were experienced in nuclear power facility
RP and radwaste activities. The documents which were reviewed are listed
in the Attachment to this report.
No violations or deviations were identified.
18.
Exit Meeting
The inspectors met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on
"
February 2, 1990.
The inspectors summarized the inspection findings as
presented in this report. The licensee did not identify as proprietary
any of the materials provided to, or reviewed by, the inspectors during
the inspection.
.
.
e,
!
. .. .
i
ATTACHMENT
ARKANSAS NUCLEAR ONE
NRC INSPECTION REPORT:
50-313/90-04 and 50-368/90-04
.
Documents Reviewed
1.
Quality Assurance (QA) Audits and Surveillances
!
QA Audit Report, QAP-1-88, " Radioactive Waste." performed November 7,
'
1988, through February 22, 1989.
QA Audit Report, QAP-2-88, " Dosimetry," performed July 27, 1988, through
November 14, 1988.
QA Audit Report, QAP-3-88, " Health Physics," performed May 25, 1988,
through September 30, 1988.
QA Audit Report, QAP-3-89, "Special Health Physics," performed April 17,
1989, through June 6, 1989.
QA Surveillance Report (QASR)89-008, " Unit 1 Reactor Building Purge
,
Sampling and Analysis," conducted January 22, 1989.
,
QASR 89-009, " Sampling and Analysis of Liquid Radwaste," conducted
January 22, 1989.
QASR 89-107, "H,P. Pre-Job Briefing," conducted September 27, 1989.
'
,
QASR 89-111 "ALARA Practices," conducted September 22, 1989.
l
QASR 89-112. " Personnel Contamination," conducted September 20, 1989.
QASP,89-121, " Unit 2 Reactor Building Posting and Radiological Controls,"
conducted September 30, 1989,
i
'
QASR 89-130, " Radiological Controls - Unit 2 Auxiliary Building,"
conducted October 5, 1989,
t
QASR 89-134, " Sampling on SPINGS," conducted October 12, 1989.
QASR 89-141, " Hot Particle Detection and Control," conducted October 13,.
1989.
'
QASR 89-149, " Control Point Activities," conducted October 21-25, 1989.
QASR 89 153, " Sampling al.d Analysis of 2T69A," conducted October 26, 1989.
QASR 89-165, " Control of Radiography," conducted November 11-12, 1989.
.
'-
s
Nc
,
_ _ _ _ . ._-
_ _ _ _ - _ _ .
e
o
<s
o
-2-
.
.
QASR 89-177, " Radiological Postings in the Unit 1- Reactor Building,"
conducted Decembqr 7, 1989.
0ASR 89-189, "HP Job Coverage During Primary Sampling," conducted
December 29- 1989.
2.
Procedures
Number
Title-
Revision Date
I.
1000.031
. Radiation Protection Manual
9
11/24/89
L
.3000.107
High Radiation Area Control
-3
07/27/89
L
1012.005
Hot Particle Detection and Control
2
09/26/89
1012.014
Health Physics Area Inspections
0
11/24/89-
1012.001
Health Physics Shift Turnover Log
2
05/14/88
1012.002
Contract HP Technician Selection
0
08/14/89
t
1612.001
Mock Up Training
3
05/16/89
1612.003
Radiation Work Permits .
17
11/17/89
. .
1612.006
Control of Temporary Shielding
7
08/19/89
.
~1612.008
Radiological Containments
0
07/29/88
1612.023
Investigation of High Unusual Exposures
0
09/26/89
1612.024
Assignment of Dose From Skin Contamination
0
08/14/89
'1622.003
.RA0 Posting and Cotry Requirements
11
09/16/89~
1622.006
RA0 Air Sampling-
11
.10/20/89
.1622.010
Personnel Decontamination
15
11/17/89
1622.019
Selecting a Survey Meter
5
09/01/89-
.
.,
,
.
'
Sze