ML20058D549
| ML20058D549 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/23/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058D502 | List: |
| References | |
| 50-313-93-30, 50-368-93-30, NUDOCS 9312030196 | |
| Download: ML20058D549 (10) | |
See also: IR 05000313/1993030
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Inspection Report:
50-313/93-30
50-368/93-30
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Operating Licenses: -DPR-51
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Licensee:
Entergy Operations, Inc.
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Operations, Arkansas Nuclear One
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Route 3, Box 137G
Russellville, Arkansas 72801
Facility Name: Arkansas Nuclear One
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Inspection At:
Russellville, Arkansas
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Inspection Conducted: November 1-5, 1993
Inspector: Anthony D. Gaines, Radiation Specialist
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Facilities Inspection Programs Section
Approved:
/ & M)
2kI1OMI
W Vf)
8. Murray, Chi Af, Firtt1fties Inspection
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Programs Section
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Inspection Summary
Areas Inspected: Routine, announced inspection of the radiation protection.
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program, including audits and appraisals; changes; planning and preparation;
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training and qualifications of personnel; external exposure control; internal.
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exposure control; control of radioactive' materials and contamination, surveys,
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and monitoring; and maintaining occupational exposure ALARA.
Results:
Very good surveillances were performed by qualified individuals
(Section1.1).
Only minor personnel changes had been made since the last NRC inspection
of this area (Section 1.2).
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Outage Management performed an excellent job of preparing for and
defining the scope of the IRll outage (Section 1.3).
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Contract radiation protection technicians were qualified and trained
appropriately (Section 1.4).
9312030196 931129 7
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ADOCK 05000313
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One violation was identified involving workers who did not wear alarming
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dosimeters as specified in the radiation work permit. Overall, external-
radiation exposure controls were generally good (Section 1.5).
Good internal exposure controls were implemented (Section 1.6).
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Respirator use during the outage was significantly reduced (Section 1.6).
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A good decontamination effort was performed at the start of the outage
(Section 1.7).
One violation was identified for the failure to survey radioactive-
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contaminated drums prior to their disposal offsite. Controls of
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radioactive materials and contamination, surveys, and monitoring were
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generally good (Section 1.7).
Excellent ALARA planning and preparation were performed for 1Rll
(Section 1.8).
Reduction in worker exposure during the outage was excellent
(Section 1.8) .
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Inspection Findina:
Violation 313/9330-01; 368/9330-01 was opened (Section 1.5).
Violation 313/9330-02; 368/9330-02 was opened (Section 1.7).
Violation 313/9211-02; 368/9211-03 was closed (Section 2.1).
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Attachment:
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Attachment 1 - Persons Contacted and Exit Meeting
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DETAILS
1 OCCUPATIONAL RADIATION EXPOSURE (83750 and 83729)
The licensee's program was inspected to determine compliance with Unit 1
Technical Specifications 6.3, 6.8, 6.10, and 6.11; Unit 2 Technical
Speci fications 6.3, 6.8, 611, and 6.13; and the requirements of 10 CFR
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Part 20 and agreement with the commitments of Chapter 11 and 12 of the Final
Safety Analysis Reports for Unit 1 and 2, respectively.
1.1 Audits and Acrraisals
The inspector noted that no audit was scheduled or had been performed sin e
the last inspection of this area in May 1993. There had been eight
surveillances performed since the last inspection. The surveillances were
reviewed and were noted to be of very good quality. Qualified personnel
performed the surveillances.
1.2 Chanaes
There had been only minor personnel changes in the radiation protection
organization since it was reviewed in NRC Inspection Repart 50-313/93-05;
50-368/93-05. The changes mainly included the shifting of health physics
operations supervisors to different positions, and one health physic:
supervisor position was vacant due to the resignation of one individual. The
changes did not adversely affect the radiation protection program.
1.3 Plannina and Preparation
The licensee supplemented the permanent radiation protection staff with
approximately 65 senior radiation protection technicians and 22 junior
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radiation protection technicians during the IR11 refueling outage. The
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contract technicians were brought in early in order to complete onsite
training. The contract force included a large number of persons who had
worked previous outages at Arkansas Nuclear One.
The inspector determined that the licensee had ample supplies of temporary
shielding, radiation detection instrumentation, air monitoring equipmerit,
portable ventilation, and protective clothing to support outage activities.
Outage Management performed an excellent job of planning for the IRll outage.
The scope of IRll was defined approximately 24 weeks prior to the start of the
outage which allowed adequate time for review by all departments, especially
ALARA. Detailed radiological controls reviews of outage related activities
were performed.
1.4 Trainina and Qualifications of Personnel
The licensee used a screening examination to aid in the selection of contract
radiation protection technicians. The inspector reviewed selected records of
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contract technicians and noted that the individuals had passed the screening
examination with the appropriate score to be a senior or a junior radiation-
protection technician.
The licensee had established very good procedural guidance for assessing the
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experience of contract personnel. The inspector reviewed selected resumes of
contract radiation protection technicians and determined that they met
qualification requirements.
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Selected training records of contract radiation protection technicians were
reviewed, and the inspector noted that the individuals had been given
appropriate training.
1.5 External Exposure Control
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The inspector observed individuals entering the radiological controlled area
and noted that they wore appropriate personnel monitoring. A review of
records indicated that personnel that were required to use multi-badging
during the refueling outage were issued multiple dosimeters.
Radiation work permits provided appropriate guidance to individuals working in
the radiological controlled area. Worker compliance with radiation work
permit requirements was generally good; however, the inspector noted the
following exception.
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The inspector reviewed Radiation Work Permits 930553 and 930311 pertaining to
work on the pressurizer code safety valves and the primary steam generator
manways respectively and noted that the permits required all workers to wear
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an alarming dosimeter. However, when the inspector compared a list of
individuals making entries into the radiological controlled area utilizing
Radiation Work Permits 930553 and 930311 with lists of individuals who were
issued alarming dosimeters, the inspector noted that two individuals (one on
each permit) had not been issued alarming dosimeters as required. The
inspector reviewed the iicensee's radiological information reports from
July 1993 to the present and noted three instances of individuals not wearing
their alarming dosimeters as required by the radiation work permit and five
instances of individuals entering the r4diological controlled area without
self-reading dosimeters as required by the radiation work permit. The
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inspector reviewed previous NRC Inspection Reports and noted that
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Violation 313/9211-02; 368/9211-03 for failure to follow radiation work permit
requirements was still open. This violation had been reviewed in NRC
Inspection Report 50-313/93-03; 50-368/93-03 and left open because of
instances of individuals not following radiation work permit requirements by
entering the radiological controlled area without self-reading dosimeters.
Technical Specification 6.8.1.a for Units 1 and 2 required that written
procedures be established, implemented, and maintained covering the applicable
procedures recommended in Appendix A of Safety Guide 33 and Regulatory
Guide 1.33 respectively, which, in turn, recommends radiation work permits be
covered by procedures. Procedure 1000.31, " Radiation Protection Manual,"
stated that individuals are responsible for adherence to radiological
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protection requirements and being knowledgeable and understanding the
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requirements and contents of the radiation work permit under which work will
be performed. The failure to adhere to radiation work permit requirements is
considered a violation of Technical Specification 6.8.1.a. (313/9330-01;
368/9330-01).
The inspector made several tours of the radiological controlled area,
including containment, and observed that areas were properly posted and
controlled.
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1.6 Internal ExDosure Control
The inspector reviewed respiratory protection equipment issue records and
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verified that the individuals who were issued respiratory protection equipment
met qualification requirements and that they received equipment of the proper
size.
The licensee used portable ventilation units with high efficiency particulate
filters where practical as a means of reducing airborne contamination. The
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inspector noted that the licensee had reduced the use of respirators during
the outage. The licensee had reduced respirator use from approximately
11,000 respirators issued during previous refueling outages to approximately
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500 respirators for the IRll outage.
The inspector reviewed the air monitoring program and method of assigning and
tracking maximum permissible concentration hours and determined that they were
appropriate.
The inspectors noted that individuals identified with facial contamination
were routinely whole-body counted to determine if internal contamination
resulted. Licensee representatives stated that no one with internal
contamination in excess of 5 percent of a body burden had been identified
during the refueling outage.
1.7 Controls of Radioactive Materials and Contamination. Surveys, and
Monitorina
The inspector observed entrance and exit access controls at the radiological
controlled area and found them to be good. Housekeeping within the
radiological controlled area was good.
The inspector reviewed selected survey records and determined that the
licensee had implemented a good radiation area survey program.
Survey results
were documented properly.
Independent surveys performed by the inspector were
in good agreement with surveys performed by the licensee. The licensee had a
good supply of calibrated radiatic
rvey meters. The inspector reviewed
selected survey meter calibrati.'
w'rds and noted that the meters had been
calibrated at the proper frequct..,.
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Leak test records and inventory records of sealed sources were reviewed, and
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the inspector determined that the leak tests and inventories had been
performed at the proper frequencies.
Individuals exiting the radiological controlled area were required to pass
through both gamma and beta sensitive personnel contamination monitors. Tool
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monitors were used to survey hardhats. Radiation protection personnel
surveyed handcarried items for contamination prior to release.
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Licensee representatives stated that they had identified approximately .
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436 personnel contaminations as a result of 1R11 outage activities. Licensee
representatives pointed out that this was 2.7 personnel contaminations per-
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1000 radiation work permit hours. Less than half, approximately 181, of the
personnel contaminations were skin contaminations.
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The licensee performed a good decontamination effort at the start of 1R11.
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The decontamination allowed the licensee to use less plastic personnel
contamination clothing. This, combined with the use of washable laydown mats
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and reusable mesh bags for tools, contributed to a reduction in the amount of
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waste generated during the outage. The licensee also made excellent use of a
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nondestructive cleaning unit which used frozen carbon dioxide pellets to bead
blast and decontaminate various items including approximately 523 cubic feet
of noncompactible dry active waste which was later free-released.
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In general,' surveys, monitoring, and releases of potentially contaminated
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material to unrestricted areas were appropriate. However, prior to the
inspection, the licensee notified the NRC Region IV staff of an event
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involving two drums containing a freon-based solvent which had been released
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offsite as waste material and were later found to contain radioactive
material. This event was documented by the licensee in Condition
Report C-93-0120.
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A review of Condition Report C-93-0120 indicated that on August 18, 1993, the
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two drums were packaged in overpacks and transported to an offsite freon
recycling facility.
Because of the condition of the drums, on August 23,
1993, this facility sent the drums to another facility to repackage the liquid
in smaller drums. Only one of the drums and part of the other were emptied
due to the lack of enough smaller drums. The emptied drum was sent back to
the first facility on September 24, 1993, where it was crushed and sent to a
scrap metal facility with other scrap. The scrap metal facility performed a
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routine radiation survey of the incoming scrap material that contained the
drum and noted an increased survey meter response near the drum. Since this
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facility was not licensed to receive radioactive material, the scrap metal
facility rejected the load and sent it back to the first recycling facility,
who then contacted the licensee. The licensee promptly dispatched radiation
protection technicians to the offsite location who surveyed and recovered all
of the radioactive material. The highest dose rate was found on the bottom of
one of the original drums and was approximately 2.6 millirem per hour on
contact and 0.3 millirem per hour at one foot. The other drums ranged from
0.02 to 0.4 millirem per hour on contact. The licensee performed a dose
estimate of the individual that would have been most exposed and noted that .
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the person's dose would have been 0.075 millirem.
An isotopic analysis of
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the solvent performed by the licensee indicated that the solvent contained
cobalt-60, cesium-134, and cesium-137.
The licensee performed a good review of the incident but could not determine
when the material was broughi,on site or where it had been used. The material
was thought to have been left by vendors after an outage.
In 1986 when the
plant established the Consumable Chemical Material Control Program, the drums
were added to the list of chemicals. The solvent had been stored at the
Arkansas Nuclear One oilhouse since 1986, and in February 1993, the two drums
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were relocated to the hazardous materials storage area to be dispositioned.
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Based on the facts that there were no records of the materials used, the
containers were still full, the liquid was still packaged in the
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manufacturer's supplied containers, and the material was being stored in a
nonradiologically controlled area, the licensee's taff believed that the
solvent was new and unused.
10 CFR 20.201(b) requires that each licensee make such surveys as may be
necessary to comply with the requirements of Part 20 and which are reasonable
under the circumstances to evaluate the extent of radiation hazards that may
be present.
In addition, 10 CFP,20.301, -Waste Disposal," requires that no
licensee shall dispose of licensed material except by transfer to an
authorized recipient. As defined in 10 CFR 20.201(a), " surveys" means an
evaluation of the radiation hazards incident to the production, use, release,
disposal, or presence of radioactive materials or other sources of radiation
under a specific set of conditions. The failure to perform a radiation survey
to evaluate the radiation hazard of the solvent prior to disposal is a
violation of 10 CFR 20.201(b) (313/9330-02; 368/9330-02).
The licensee identified the violation and took prompt corrective actions.
However, the licensee had been issued a noncited violation in NRC Inspection
Report 50-313/93-06; 50-368/93-06 dated August 5,1993, for a similar problem
when it released radioactively contaminated tools, some of which were released
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offsite. Also, the inspector noted that the licensee's review of the incident
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indicated that it had identified a problem with drum control in the past in
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Condition Report C-91-0075. The condition report indicated that a
radioactively contaminated drum of oil was almost sent offsite for disposal
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like the drums of solvent. The licensee's investigation and corrective
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actions associated with this condition report recognized liquid waste
collection containers as a potential source of uncontrolled and unidentified
radioactive material. As part of their corrective actions, they developed a
formalized drum control program which was embodied in Procedure 1052.025.
This was the same procedure that was used to dispose of the two drums of
solvent which indicates that the corrective actions for the previous
identified problem was not adequate. Since the August 18, 1993 event was a
repeat violation and previous corrective actions were ineffective, enforcement
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discretion allowed in the Enforcement Policy was not enacted.
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1.8 Maintainina Occupational Exposure ALARA
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The inspector noted that excellent ALARA planning and preparation was
performed for the work scheduled for 1Rll. The inspector reviewed selected
ALARA packages for jobs performed during the IRll outage and noted that they
were of good quality and included adequate checklists, estimates of projected
man-hours, radiation survey information, radiation exposure projections, and
lessons learned from previously accomplished, similar work.
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Prior to the IRll refueling outage, early boration and peroxide flushing was
used to remove approximately 1113 curies of radioactive material from the
Unit I reactor coolant system. The ALARA group estimated that 121 person-Rems
were saved during outage activities as a result of this process. Hot spot
flushing was also performed in selected areas.
A preliminary goal of 300 person-Rem was set for 1Rll.
Later, a more detailed
radiation exposure estimate was made which resulted in a goal of 215
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person-Rem with a " stretch goal" of 195 person-Rem. Final thermoluminescent
dosimeter results indicated an expenditure of approximately 182 person-Rem
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which was 13 person-Rem below the licensee's " stretch goal." The achievement
oi +his goal indicated excellent improvement by the licensce in reducing
outage radiation exposure. Some other techniques employed to reduce exposure
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besides the ones mentioned previously included: mock-up- training, the use of
telemetric dosimetry and video cameras to remotely monitor high dose work, the
use of temporary shielding to reduce radiation levels where practical, the
decreased use of respirators, and the use of limited access signs to reduce
traffic through areas of high exposure rates.
1.9 Conclusions
Very good radiological control surveillances were performed by qualified
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individuals. Only minor personnel changes had been made since the last
inspection 'of this area.
The licensee properly prepared for the IRll refueling outage by supplementing
its radiation protection staff with qualified contract personnel, removing
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radioactive material from the reactor coolant system through early boration
and peroxide flushing, and ensuring that sufficient quantities of equipment
used by the radiation protection organization were available. Outage
management performed an excellent job of preparing for and defining the scope
of the outage.
External radiation exposure controls were generally good. However, one
violation was identified, because workers did not wear alarming dosimeters.
The licensee took prompt corrective actions, but similar problems had been
previously identified.
Good internal radiation exposure controls in the form of respiratory
protection, air monitoring, and whole-body counting were implemented. An
excellent job of reducing respirator use was performed.
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A good decontamination effort at the start of IR11 was performed. Controls of
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radioactive materials and contamination, surveys, and monitoring were
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generally good. However, one violation was identified for the failure to
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survey radioactively contaminated drums prior to their disposal offsite.
Excellent ALARA planning and preparation was performed for IRll. Reduction in
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outage exposures was excellent.
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2 FOLLOWP DN CORRECTIVE ACTIONS FOR VIOLATIONS (92702)
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2.1
(Closed) Violation 313/9211-02: 368/9211-03 - Failure to Follow Radiation
Work Permit Reauirements
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This item involved three examples of failure to follow radiation work permit
requirements. This item was last reviewed in NRC Inspection Report
50-313/93-03; 50-368/93-03. The violation was not closed at that time because
of instances indicating continuing problems in the area of following radiation
work permit requirements.
In particular, individuals had entered the
radiological controlled area without self-reading dosimeters. Section 1.5 of
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this report discussed Violation 313/9330-01; 368/9330-01 which involved the
failure to follow radiation work permit requirements by not wearing dosimetry
required by the radiation work permit. Therefore, Violation 313/9211-02;
368/9211-03 is being closed and future corrective actions for this problem
will be tracked and reviewed under Violation 313/9330-01; 368/9330-01.
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ATTACIMENT
1 PERSONS CONTACTED
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1.1 Licensee Personnel
- S. Boncheff, Licensing Specialist
- R. Cantwell, In House Events Aanlysis Specialist
- S. Cotton, Manager, Radiation Protection / Radioactive Waste
- R. Espolt, Assistant Plant Manager, Unit 2
- M. Harris, Maintenance Manager, Unit 2
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D. Hicks, Supervisor, Health Physics Operations
- R. King, Acting Director, Licensing
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- B. McKelvy, Chemistry Superintendent
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D. Moore, Health Physics Superintendent
- S. Pyle, Licensing Specialist
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- D. Snellings, Superintendent, Radiation Protection Technical Support
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- D. Stolz, Raciation Protection Outage Planner /ALARA
- J. Taylor-Brown, Coordinator, Quality
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- J. Vandergrift, Plant Manager, Unit 1
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1.2 NRC Personnel
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L. Smith, Senior Resident Inspector
S. Campbell, Resident Inspector
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- Denotes personnel that attended the exit meeting.
In addition to the
personnel listed, the inspector contacted other personnel during this-
inspection period.
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2 EXIT M ETING
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An exit meeting was conducted on November 5,1993. During this meeting, the
inspector reviewed the scope and findings of the report. The licensee did not
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identify as proprietary, any information provided to, or reviewed by the
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inspector.
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