IR 05000313/1993030

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/93-30 & 50-368/93-30

ML20059G200
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/13/1994
From:	Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Yelverton J ENTERGY OPERATIONS, INC.
References
NUDOCS 9401240040
Download: ML20059G200 (4)

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j ?g NUCLEAR REGULATORY COMMISSION  !

j3l REGION IV

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...- JAN I 31994 Dockets: 50-313 50-368 Licenses: DPR-51 NPF-6 Entergy Operations, In ATTN: J. W. Yelverton, Vice President Operations, Arkansas Nuclear One Route. 3, Box 137G R:asellville, Arkansas 72801

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SUBJECT.- NRC INSPECTION REPORT 50-313/93-30; 50-368/93-30 Thank you for your letter of December 22, 1993, in response to our letter and Notice of Violation dated November 29, 1993. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation'of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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Dwight D. Chamberlain i Acting Director Division of Radiation Safety and Safeguards cc:

Entergy Operations, In ATIN: Harry W. Keiser, Executive Vice President & Chief Operating Officer P.O. Box 31995-Jackson, Mississippi 39286-1995

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Entergy.0perations, In Entergy Operations, In ATIN: John R. McGaha, Vice President ,

Operations Support P.O. Box 31995 Jackson,. Mississippi 39286 Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es ,

P.O. Box 651 Jackson, Mississippi 39205

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Honorable C. Doug Luningham County' Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 ,

Winston & Strawn ATTN: Nicholas S. Reynolds, Es L Street, Washington, ,

Arkansas Department of Health ATTN: Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management t 4815 West Markham Street ,

Little Rock, Arkansas 72201-3867 B&W Nuclear Technologies  ;

ATTN: Robert B. Borsum  !

Licensing Representative 1700 Rockville Pike, Suite 525  ;

Rockville, Maryland 20852 Admiral Kinnaird R. McKee, USN (Ret)  ;

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214 South Morris Street 0xford, Maryland 21654 ABB Combustion Engineering Nuclear Power ATTN: Charles B. Brinkman ,

Manager, Washington i Nuclear Operations  ;

12300 Twinbrook Parkway, Suite 330 '

Rockville, Maryland 20852

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.i Entergy Operations, In bcc.to DMB (IE06)-

bec w/ copy of letter dated December 22, 1993:

J. L. Milhoan A. D. Gaines, DRSS/FIPS AN0 Resident Inspector Section Chief (DRP/D)

Section Chief (DRP/TSS)

Project Engineer (DRP/0)

Lisa Shea, RM/ALF, (MS MNBB 4503)

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Entergy Operations, In bec to DMB (IE06)

bec w/ copy of letter dated December 22, 1993:  :

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J. L. Milhoan A. D. Gaines, DRSS/FIPS AN0 Resident Inspector *

Section~ Chief (DRP/D)

Section Chief (DRP/TSS) ,

Project Engineer (DRP/D) l Lisa Shea, RM/ALF, (MS MNBB 4503)

DRSS/FIPS Files MIS System RIV File

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Ent;rgy Oper;tions, In '

c =- ENTERGY Route 3 Box 137G n ma no Tet 50196A8688

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Jerry W. Yelverton Vce Pescent 0: cam ANO December 22,1993  ; -

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OCAN129304 61

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U. S. Nuclear R gulatory Commission ,

Document Control Desk '

i;EG!CN IV Mail Station PI-137 '

Washington, DC 20555 Subject: Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Report 50/313/93-30; 50/368/93-30 Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the violations identified during the inspection of activities associated with the failure to follow radiation work permit requirements and the failure to perform radiation survey '

Should you have questions or comments, please call Mr. Rick King at 501-964-861 Very truly yours,

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December 22,1993

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cc: Mr. James L. Milhoan Regional Administrator U. S.. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-l & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. Roby B. Bevan, J NRR Project Manager Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Thomas W. Alexion NRR Project Manager, Region IV/ANO 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852

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. NOTICE OF VIOLATION During an NRC inspection conducted on November 1-5, a routine, announced inspection of the radiation protection program, two violations of NRC requirements were identifie !

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A. Unit I and Unit 2 Technical Specification 6.8.1.a requires, in part, that written

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procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A, states, in pan, that radiation work permits be covered by written procedure Section 5.5 of Procedure 1000.031, Revision 16, " Radiation Protection Manual,"

states, in part, that " individuals are responsible for: adherence to radiological protection requirements " and " ..being knowledgeable of an understanding the requirements and contents of the Radiological Work Permit under which work will be performed."

Radiation Work Permits 930553 and 93031I state, " Alarming Dosimeters are required for entry on this Radiological Work Permit."

Contrary to the above, on November 3,1993, the inspector identified two individuals who entered the radiological controlled area under Radiation Work Permits 930553 and 93031I who had not been issued alarming dosimeter This constitutes a Severity Level IV violation (Supplement IV) (313/9330-01; 368/9330-01).

B.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. 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 condition Contrary to the above, the licensee identified that on August 18,1993, surveys were not made to assure compliance with 10 CFR 20.301, which describes authorized means of disposing oflicensed material contained in waste. Specifically, a radiation survey was not performed of two drums of solvent prior to shipment to an oilsite facility for disposal. Subsequent surveys identified radiation levels of between 0.02 to-2.6 millirem per hour on contact with the drum This constitutes a Severity Level IV violation (Supplement IV) (313/9330-02; 368/9330-02).

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. Response to violation 313/9330-01: 368/9330-01) Failure to Adhere to Radiation Work Permit Requirements (1) Reason for the violation Three events related to alarming dosimeter events had been previously identified by Radiation Pratection personnel and corrective actions with involved individuals were completed. However, the established Radiological Information Report (RIR)

threshold requiring funher trend analysis of alarming dosimeter infractions had not yet been met. A follow-up review of Arkansas Nuclear One (ANO) Radiation Work Permit (RWP) records and RIRs revealed similar instances of individuals ,

who entered radiological controlled areas (RCA) without either preparing the proper documentation for issue, or receiving the required alarming dosimeter The majority of these non-compliance's occurred during the Fall of 1993, in Arkansas Nuclear One (ANO) Unit I refueling outage 1Ril, by contract personne The reason individuals entered RCA without the required alarming dosimeters was inadequate compliance with the RWP regarding the proper radiation worker practice Additionally, the following contributing causes compounded the alarming dosimeter problem:

. Inadequate communication between Health Physics (HP) technicians and radiation workers concerning entry requirements during radiography sessions,

. Inattention to detail by radiation workers during preparation for entering, and working in high rad areas, t

. Inconsistent wording in RWPs relating to alarming dosirneter requirements, and,

. Inadequate performance by HP clerks in documenting the issue of alarming dosimeters (2) Corrective steps taken and results achieved:

On November 8,1993, a memorandum from ANO Executive management was issued outlining the management expectations and required accountability in adhering to RWP requirements of all ANO and contract radiation workers. Other weaknesses in radiation worker practices were also identified and discusse During Unit I refueling outage 1Ril, HP clerks were counseled on the procedural method of documenting the issue of alarming dosimeter .

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On November 10,1993, alarming dosimeter issuance requirements were discussed with HP technician (3) Corrective steps that will be taken to prevent further violations:

The Entergy Radiation Information Management System (ERIMS) is currently under development, and when implemented on January 1,1994, is expected to provide enhanced access control into the RCA. This system will replace the Radiation Exposure Management System (REM) currently in operation. ERIMS will include a simplified RWP form that clarifies and improves human performance factored requirements for radiation worker This also includes clearer requirements for the use of alarming dosimeters. Additionally, ERIMS will track radiation worker exposure histories, dosimeter issue, et General Employee Training (GET) will be enhanced prior to the Unit 2 refueling outage 2R10 to include additional emphasis on compliance to RWP instructions and the use of alarming dosimeter During ANO Unit 2 refueling outage 2R10, currently scheduled for the Spring of ;

1994, the ANO Quality Department will perform periodic observations of radiation worker practices to validate the effectiveness of corrective actions taken concerning the use of alarming dosimeter Any individual identified as violating RWP dosimetry requirements during the Unit 2 refueling outage 2R10 will be referred to the individuals appropriate level of :

I management for corrective action. This will enforce accountability for individual action ;

(4) Dale when full compliance will be achieved:

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ANO is cunently in compliance with requirements regarding the use of alarming l dosimeter !

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. Resoonse to violation 313/9330-02: 368/9330-02) Failure to Perform Radiation Surveys (1) Reason for the violatinD NRC Inspection Report (IR) 93-06, dated August 5,1993, issued a non-cited violation for the self-identified release of contaminated tools and equipment from the ANO RCA. As stated in IR 93-06, ANO took prompt and effective corrective actions to correct the problem. One corrective action was to perform a site-wide survey of maintenance tools and equipment. This survey identified contaminated maintenance tools and equipment stored outside of the RCA. ANO continues to perform periodic surveys of non-radiological areas to ensure that contaminated material is not inadvertently released from the RCA. However, the scope of the site-wide survey did not include surplus material stored outside of the RC Procedure 1052.025, revision 0, Drum Control addresses the storage, use, analysis of contents and disposal of drums, both radiological and non-radiological. This procedure also allows documented deviations from procedural requirements when

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justified, i.e. non-performance of radiological analysi In early 1993, two 55 gallon drums of what appeared to be new and unused freon based solvent were deemed surplus and scheduled for removal from ANO. Since the solvent had no record of use, was in full original containers, and stored since 1986 in non-radiological or hazardous material storage areas, the decision not to perform a radiological analysis before disposal was made as allowed by Procedure 1052.025. These drums were then shipped to an off-site vendor for disposal on ,

August 18,199 The reason the radioactive solvent was shipped to an off-site vendor for disposal, without radiological analysis was inadequate procedural guidance. Procedure 1052.025 was developed in early 1992, which addressed the issues associated with waste liquids, but did not address or recognize other avenues ofliquid use and controls at ANO. As a result, the solvent was not interpreted to be waste, but rather surplus liquid material which was not covered by procedural requirements.

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(2) Corrective steps taken and results achievei l On September 24, 1993, ANO was notified by the vendor of the potentially l contaminated solvent. ANO Health Physics technicians were dispatched to the - ,

facility and confirmed that the solvent was radioactive. The radioactive solvent j was recovered and returned to ANO. Additionally, dose calculations of the ;

vendors employees indicated that radiation exposures were less than 1.0 mr, and

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the off-site facilities were found to be free from contaminatio Radiation and contamination surveys were performed in the oil and hazardous ,

material onsite storage areas and in an off-site warehouse. The surveys did not identify any contaminated items. Liquid materials received in the hazardous materials area are now analyzed for contamination before storag Subsequent to the offsite shipment of radioactive solvera, this event was discussed with members of the Radiation Protection staffin late September 199 Procedure 1052.025, Dnim Control, was revised on December 14,1993, to include additional guidance concerning more definitive instructions on when ,

exceptions to the procedure can be made, and to analyze material in site issued ,

drums for radiological content before shipment offsit ANO Contract Managers are provided a checklist of procedural references and requirements / activities to consider when preparing contract request On December 7,1993, the Contract Manager Guidelines were revised to address activities involving the handling, sampling, or shipment ofliquid materials into or out of the ANO protected area. This will provide improved controls to assure that contractors are appropriately notified and adhere to ANO requirements concerning the handling, sampling or shipping ofliquid material (3) Corrective stens that will be taken to orevent further violations: ,

Procedure 1000.031, Radiation Protection Mamial, was revised to provide specific guidance for sampling ofliquids prior to disposal off-sit Procedure 1012.020, Radioactive Material Control, was revised to establish guidelines for liquid sampling requirements of materials removed from posted radiological area The above procedures will be implemented on January 1,1994, which coincides with the implementation of the revised 10CFR20 which is effective on January 1, 199 .

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' Training on this event will be incorporated into the Health Physics Continuing Training Program with emphasis on Health Physics management expectations on the performance of quarterly surveys. Specific emphasis will be placed on survey of all potential storage containers (i.e. drums, barrels, boxes, etc.), stockpiled j materials common to use in the RCAs (i.e. scaffolding, treated wood, lead, etc.),

and use of high sensitivity monitoring equipment. This training will be completed by April 1,199 Other liquid containers that have been identified by the Materials Management group and those currently stored in the HazMat area will be analyzed to identify any other containers which may contain contaminated material. This analysis will ;

be completed by March 1,199 :

An effectiveness review of the corrective actions performed to prevent recurrence ;

of this event will be completed by June 1,199 l

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(4) Date when full comoliance will be achieved:

For the subject container shipped offsite, full compliance with NRC regulations was satisfied when the radioactive material was recovered, and returned to AN Additionally, due to the low exposure rates, the shipment of this. radioactive material posed no undue risk to the health and safety of the general publi ;

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