ML20136F695

Insp Rept 50-331/97-02 on 970210-14.Violation Noted.Major Areas Inspected:Radioactive Matl Transportation Program, Training & Qualifications of Personnel & Transportation of LSA Matl,Sco & Hpts Surveys

ML20136F695
Person / Time
Site:	Duane Arnold
Issue date:	03/06/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136F619	List: ML20136F615 ML20136F643 ML20136F695
References
50-331-97-02, 50-331-97-2, NUDOCS 9703170025
Download: ML20136F695 (12)

See also: IR 05000331/1997002

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U. S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket No: 50-331

License No: DPR-49

Report No. 50-331/97002(DRS)

Licensee: IES Utilities Inc.

Facility: Duane Arnold Energy Center

Location: 200 First Street S.E.

P. O. Box 351

Cedar Rapids, IA 52406-0351

Dates: February 10-14,1997

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inspector: Kara N. Selburg, Radiation Specialist

Approved by: Thomas J. Kozak, Chief, Plant Support 2

Division of Reactor Safety

9703170025 970306

PDR ADOCK 05000331

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Reoort Details

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Plant Suonort

) R1 Radiological Protection and Chemistry (RP&C) Controls

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R 1.1 Trananortation of Radioactive Material

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a. Insoection Scone (86750, 2515/133)

l The inspector reviewed the licensee's radioactive material transportation program in

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accordance with Temporary Instruction 2515/133, " Implementation of Revised 49

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CFR Parts 100-179 and 10 CFR Part 71." This review included an assessment of

training and qualifications of personnel, transportation of low specific activity (LSA)

materials and surface contaminated objects (SCO), expansion of the radionuclide

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list, changes in radioactive limits, use of the international system (SI) of units, and

j classification of fissile material.

i b. Observations and Findinos

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The inspector reviewed the licensee's training program and it's incorporation of the

updated transportation regulations. All qualified shippers, one radioactive waste

(radwaste) trainer, and some radwaste operators attended vendor courses detailing

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several of the regulation changes. All radwaste operators attended continuing

training which described the changes to the regulations and the effects on specific

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job activities. Health physics technicians (HPTs) responsible for radiological surveys

on shipments were not required to attend training in this area. All work performed

by HPTs was directed and reviewed by qualified shipping personnel. Overall,

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personnelinterviewed were very knowledgeable of the transportation process and  !

the updated regulations. The inspector noted that training in this area was  ;

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The inspector reviewed the licensee's procedures for transporting LSA material and

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SCO. The procedures had been thoroughly updated to reflect the new regulations.

The inspector reviewed the licensee's site-specific definition of SCO which was

' developed to provide guidance during SCO shipments. The definition was

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consistent with DOT regulations. The inspector reviewed the shipping papers

associated with the only SCO shipment completed by the licensee; no problems

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2- were identified. The inspector also reviewed shipping papers associated with LSA

material shipments, including a review of the "Too Tall" high integrity container

(HIC). During the preparation of an August 1996 shipment, the licensee discovered

that this HlC would not fit into an NRC certified cask. To complete the shipment,

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the licensee changed the cask from an NRC certification to a DOT type 7A

i certification. The inspector verified that the correct testing was performed to

j certify the cask as a DOT type 7A cask.

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' The licensee's transportation computer program had the current table of A,/A 2

values for radionuclides installed to ensure that packages would not exceed their

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allowable quantities. The inspector independently verified selected Ai /A, values

generated from the computer code, including cobalt 60, zinc-65, cesium-137, and

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plutonium-241 and verified that the new values had been implemented. The

inspector observed the shipping coordinator operate the computer code and

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~ produce the appropriate shipping papers. No problems were encountered while  !

using the code.

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The inspector verified that the licensee had effectively implemented the use of SI

units for the preparation of shipping documents and emergency response

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information which accompanies the radioactive material shipments. The licensee

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did not have any procedures governing the transportation of non-exempt fissile

material. While the licensee had not shipped this type of material since the

implementation of the new regulations, during the next refueling outage (spring

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1998) the licensee is anticipating shipments in this category. The licensee planned

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to create a procedure prior to transporting any non-exempt fissile material.

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i c. Conclusions

F Overall, the licensee had effectively implemented the new transportation

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, R1.2 Solid Radioactive Wagg

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a. Insnection Scone (86750)

The inspector reviewed the licensee's solid radioactive waste program including

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radwaste storage, processing, characterization and classification, and the conduct

' of radwaste operators. The inspector performed routine inspections of the low

level radwaste building, including the radwaste control room. The inspector also

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reviewed selected documents, and interviewed various radwaste personnel,

b. Observations and Findinas

The inspector performed routine inspections of the licensee's low level radwaste

building. All radioactive material stored was appropriately marked and labeled.

Confirmatory surveys determined that all radiation levels indicated on radioactive

material tags were appropriate. The inspector noted the licensee had shipped all of

the resin stored in the resin storage vault in 1996 to the low level waste burial

facility in Barnwell, SC with the exception of one HIC containing water and a

chemical decontamination backwashable filter. This HIC will remain on site until

enough reactor water cleanup resin is generated to fill the HIC.

The licensee's final safety analysis report stated that resin could be dewatered or

solidified on site. No solidification was occurring on site: however, the licensee

maintained the capability to complete this process. The licensee did dewater resin

on site prior to shipment. This was completed in accordance with vendor

procedures, which were approved and controlled by the licensee. No problems

were noted in this area

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The inspector reviewed a radwaste operations tumover on 2/13/97. The turnover

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illustrated good communication, and a clear expression of the system configuration

and activities encountered during the shift. Radwaste operators interviewed were

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The inspector reviewed the licensee's procedures and documentation to ensure that

necessary samples were taken for compliance with 10 CFR 61. The licensee's

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program included periodically taking samples for analysis for wet homogeneous

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' solid wastes, liqu;d wastes, dry active waste (DAW), and water filter media. The

samples were taken biannually for Class A waste, and annually for Class B or

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greater waste. New samples would be taken if changes in water chemistry, failed

fuel fraction, major CRUD bursts, or other operational problems occurred. The

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samples were analyzec by the chemistry department and by a vendor laboratory to

' quantify specified nuclide an.J generate isotopic ratios (scaling factors) for -

determining difficult to measure isotopes. The inspector reviewed the most recent

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' scaling factors and identified no problems. The licensee obtained numerous 10 CFR

61 samples during the fourteenth refueling outage (RF014), and planned to shipped

' the samples in early 1997. Condensate, torus and DAW 10 CFR 61 calculations

were completed during the fourth quarter of 1996.

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The inspector reviewed the licensee's 10 CFR 61 trending analyses. A reactor

coolant gamma analysis was performed quarterly and documented on a trending

table which was maintained by the radwaste shipping coordinator. If the reactor

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coolant principle nuclide changed by a factor of ten, the licensee would investigate

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the cause and determine if a new 10 CFR 61 analysis was necessary. The licensee

[ also trended key nuclides. The key nuclides (cobalt-60 and cesium-137) were used

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to establish scaling factors for difficult to measure radionuclides. A sample taken

from each shipment of condensate resin and reactor water cleanup resin was used

to determine the specific key nuclide ratio. This ratio was trended and compared

against the baseline ratio, and would be investigated if the ratio changed by a

, factor of ten.

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' The inspector reviewed the licensee's trending results from October 1994 to the

present. The inspector noted that the key nuclide ratio had changed by greater

than a factor of ten in August 1996 in the condensate waste stream. This change

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! was attributed to the reduction of cobalt concentration while the ceslum

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concentration remained constant. The licensee responded to this change in

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accordance with their procedures and no problems were noted. The licensee also

investigated one unusually high cobalt-60 to cesium-137 ratio in a condensat ain

HIC in January 1996. Although the ratio did not exceed the factor of ten

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requirement, the licensee performed an investigation to obtain a thorough

understanding of the situation. The inspector reviewed this investigation and

l identified no problems. The licensee's process appeared to be consistent with

i NRC's " Final Waste Classification and Waste Form Technical Position Papers."

The inspector reviewed the reactor water chemistry factors following the injection

of noble metals during RF014 to determine if any significant changes had occurred.

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] There was a small increase in activated corrosion products (manganese-54, cobalt-

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60) for cpproximately one week following plant start-up; however, these values

returned to levels consistent with those observed prior to noble metal injection.

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The reector water lodine dose equivalent was trending lower following the noble

' metal injection, and the licensee is currently investigating this trend with General

Electric.

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c. Conclusions

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Overall, the licensee's solid radwaste program was effective. Storage facilities

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were well maintained and radweste workers were knowledgeable of their systems.

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The licensee effectively trended parameters to ensure the 10 CFR 61 waste -

classification requirements were met.

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f- R1.3 Radioloaical Performance Durina Outaaes

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j- a. h)gDection Scooe (83750)

The inspector reviewed the post-RFO14 and the post-forced outage ALARA

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reviews. The inspector discussed these areas with various radiation protection

personnel, and reviewed selected ALARA documents.

b. Obaarvations and Findinas

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The inspector noted that the licensee had completed a thorough post-outage

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encountered and lessons learned. RF014 personnel dose was 190.8 rem. This

was the licensee's lowest refueling outage dose since 1976. The savings were

attributed to several factors, including: completion of the first full cycle while

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injecting depleted zinc into the reactor vessel which reduced general area drywell

dose rates: good shielding coordination through assigning craft laborer / carpenter

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foreman to the ALARA group to coordinate shielding activities; and chemically

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cleaning the drywell coolers which saved approximately 5 person-rem. High dose

activities during the outage included in-service inspections (ISI) of welds in reactor

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vessel penetration areas. Unexpectedly high dose rates were encountered when

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' shielding blocks SW6 and N16A were removed for ISI activities and 8 rem was

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expended during the removal and installation of these blocks alone. Emergent work

on the RHR inject check valve and the inboard and outboard RWCU isolation valves

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added 10 rem to the outage dose. Overall, the licensee was effective in

maintaining emergent work exposure low.

A forced outage (1/11/97-1/17/97) was caused by an increase in the unidentified

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drywellleakage rate. The ALARA department was involved in the planning for

anticipated work activities. The total dose for this outage was 3.815 rem. The

major radiological work activities included work on valve V19 0197. A leak on this

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valve caused contamination levels in the area of up to 140 millirad per hour per

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smear, and difficulty in opening the valve resulted in using mechanical agitation to

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complete this work activity. Another major radiological work activity was the leak-

testing of RHR A LPCI check valve V20-0082 to investigate a " banging" noise. The

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ALARA group prepared for scaffolding, radiography, intemal inspections, and

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repairs on this valve. However, the valve passed the leak test and none of the

contingencies were performed. Exposure for V10-0197 was 782 millirem, and for

4 V20-0082 was 794 millirem.

c. Conclusions

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Overall, the inspector noted that during outage activities, the ALARA group utilized

various methodologies to maintain exposure low, and good planning and

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coordination was noted. The inspector also noted that the ALARA department

performed post-outage reviews such that lessons leamed could be used during

planning for similar activities in upcoming outages.

I R4 Staff Knowledge and Performance in RP&C

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R4.1 Poor Communication Durino Pre-lob Briefina

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a. Inspection Scope (83750?

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The inspector reviewed job coordination during the condensate demineralizer work

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performed on February 10,1997. This included interviews with HPTs, mechanical

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i maintenance (MM) workers, and cognizant supervisors. The inspector also

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reviewed the licensee's plans to improve communications between HP and MM l

personnel following several problems observed during the previous refueling outage. '

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, b. Qhservations and Findinas

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! On February 10,1997, the licensee was performing routine work on the 1T013C

condensate domineralizer. One HPT was assigned to provide job coverage during

i this work. The HPT attended the pre-job briefing and was tasked with explaining

the radiological hazards associated with the job and to discuss HP job coverage

requirements. A subsequent fact-finding review determined that the

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communications between radiation protection and mechanical maintenance

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personnel were not clear at the pre-job briefing and that the mechanics did not have

a clear understanding of when coverage was needed during the job. The personnel

performing the job signed radiation work permit (RWP) 18 which was required in

order to perform the work. Job step 3 of RWP 18 stated that prior to beginning

work, health physics shall be informed if a contaminated system will be opened.

When the workers reached the step in the procedure to lift the demineralizer dome

head (opening a contaminated system) the HPT was not present. The workers

recalled that an HPT was present during this step when they previously performed

this evolution, but they did not realize that this was a requirement. Prior to lifting

the dome head, the workers attempted to contact the HPT but were unsuccessful.

The workers then proceeded to lift the dome head without the presence of the HPT

which violated job step 3 of RWP 18.

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Adminisontive Control Procedure 1411.27, Revision 0, Step 3.5 requires that

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workers obey posted, oral, and written radiological control instructions, procedures, '

and radiation work permits including "stop work" and " evacuate" orders from HP

personnel. Failure to comply with this procedure is a violation of licensee technical i

specification 6.9.1 which requires procedures for personnel radiation protection be

prepared consistent with the requirements of 10 CFR 20 and shall be approved,  !

maintained and adhered to for all operations involving personnel radiation exposure

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(VIO 50/331/97002-01).

Corrective actions for this and previous communication problems included providing ,

more specific instructions to workers for frequently performed activities, including

condensate domineralizer activities. RWP 18, job step 3, was changed to include '

the following: (1) cbtain an oxygen sample and confined space permit prior to - '

entering pit: (2) HP to be present when lifting dome head; (3) HP to be present I

when lifting out tube sheet. The maintenance procedure covering these activities

(DEMIN-D055-01) was also revised to place specific hold pointe fnr HP coverage.

HP and MM had held one meeting in January 1997 to discuss how to improve

communications and plans were to continue these meetings. MM personnel had

discussions within their department to determine how communication could be

improved, including instructing the MM workers to describe work activities in terms

that HPTs could understand so the correct work coverage would be provided.

c. Conclusions

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Communication problems between radiation protection personnel and mechanical

maintenance were observed. These communication problems contributed to

mechanical maintenance opening a contaminated system without health physics

coverage. While actions have been taken to improve communication, a violation

involving poor communications indicated that improvement is needed in this area.

R7 Quality Assurance in RP&C Activities

R7.1 Review of Licensee Audits .

The inspector reviewed the licensee's audit of the radiation protection and

chemistry department during the third quarter of 1996. The audit appeared

thorough and the identified issues were appropriately addressed by the responsible

personnel.

R8 Miscellaneous RP&C lasues

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(Closed) Violation 50-331/96009-01: failure to leak test hoses. During an event

follow-up involving the failure of a pneumatic hose during the refueling outage, the

licensee recognized a step in the Administrative Control Procedure Number 1411.7,

Revision 3, " Hose Control Procedures," regarding a leak test to be completed by

mechanical maintenance on an eighteen month cycle (for breathing air hoses and  :

plant service hoses) was not being performed. The licensee reviewed the need for

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the leak test requirement with a hose vendor and determined that such a test was

not necessary for the hose applications used at the plant. The inspector verified

that the step was removed from the procedure. Select licensee personnel received

training from a hose vendor on the appropriate visual and texture inspections of

hoses, and on the proper application of hoses. The licensee had scheduled training

on hose inspections for February 27,1997, to be attended by personnel from

maintenance, training, decontamination, and quality assurance departments. Hose

inspection techniques were planned to be discussed during mechanical maintenance

continuing training in the second quarter of 1997. To aid in the prevention of

future hose disconnections, the licensee started to double band hoses and use a "J-

hook" to increase the strength of the band. A " classic air tool" was ordered by the

licensee to aid in the more uniform banding of hoses. The inspector concluded that

the licensee's corrective actions regarding failing to follow the hose control

procedure were appropriate. This item is closed.

Manaaement Meetinas

X1 Exit Meeting Summary

On February 14,1997, the inspector presented the inspection results to licensee

management. The licensee acknow!cdged the findings presented. The inspector asked the

licensee whether any materials examined during the inspection should be considered

proprietary. No proprietary information was identified which led the inspector to any

conclusions detailed in this inspection report.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

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J. Franz, Vice President Nuclear  !

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G. Van Middlesworth, Plant Manager  !

P. Bessette, Manager, Engineering

i J. Bjorseth, Manager, Maintenance

D. Curtland, Manager, Operations

R. Hite, Manager, Radiation Protection

INSPECTION PROCEDURES USED

IP 83750: Occupational Radiation Exposure

IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive

Materials

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Tl 2515/133: Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71" l

ITEMS OPENED, NEW, CLOSED, AND DISCUSSED

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50-331/97002-01 VIO Failure to comply with HP instructions l

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50-331/96009-01 VIO Failure to Leak Test Hoses

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LIST OF ACRONYMS USED

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ALARA As Low As Reasonably Achievable }

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CFR Code of Federal Regulations

DOT Department of Transportation

HIC High Integrity Container

HP Health Physics

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HPT Health Physics Technician

IP Inspection Procedure

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LPCI Low Pressure Coolant injection

LSA Low Specific Activity

MM Mechanical Maintenance

! NRC Nuclear Regulatory Commission

RHR Residual Heat Removal

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RFO Refueling Outage l

RP&C Radiological Protection and Chemistry

l RWCU Reactor Water Clean-up

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RWP Radiation Work Permit

Si international System  ;

i SCO Surface Contaminated Object l

TI Temporary Instruction

VIO Violation

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Documents Reviewed "

Action Requests

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96-2653, November 25,1996, " Response to Violation in NRC IR 96009;"

97-0144, February 10,1997, " Condensate domineralizer was opened for

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maintenance without H9 present."

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Administrative Control Procedure:

RCP 1411.27 Revision 4, dated December 8,1995, " Rules for Conduct of Work in

Radiological Areas."

Chemistry Trending Graphs from 8/1/96 through 1/97:

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Offgas Pretreatment Sum of Six:

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Reactor Water Activity: Chromium 51 - Filtrate: Sodium-24 -Filtrate: Manganese-

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54 - Filtrate; Cobalt-60 - Filtrate; Cobalt 60 -CRUD; Chromium-51 -CRUD;

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Reactor Water lodine Dose Equivalent,

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Equipment Specific Maintenance Procedure:

DEMIN-DO55-01, Revision 6, "Deval, Condensate Domineralizer Tank, Filter

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Element Cleaning."

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Health Physics Forced Outage Summary, dated January 23,1997.

1 IES Utilities Shipping Papers:

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1. 96-0093;

1. 96-0097 ("Too Tall" HIC).

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IES Utilities Memos:

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" Authorization for Prepare and Verify Radioactive Material / Waste Shipping

Paperwork," File RP-9b, G-11, dated August 27,1996;

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' "HP technician Are Not DOT Hazmat Employee," memo to Russ Perry, dated

March 22,1996; '

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" Radioactive Material Shipping and Receipt Coordination, memorandum to Deb \

Schebler, Russ Perry, Diane Englehardt, File, AR-File, dated October 26,1996.

lowa Electric Nuclear Training Center, "Radwaste Operator / Environmental Monitor Tasks l

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Selected Training List."

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' Radiation Protection and Chemistry Assessment, Third Quarter Report, dated 10/16/97. i

Radiation Work Permits: '

RWP 18, Job step 3, dated 2/10/97;

RWP 18, Job step 3, dated 2/11/97.

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Radwaste Handling Procedures:

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RWH 3406.1, Revision 4, " Waste Classification and Characterization;"

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RWH 3406.6, Revision 3, " Characterizing Radioactive Material for Transport;"

RWH 3409.2, Revision 4, Sampling instructions and Analysis of Radwaste

Streams."

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Radwaste Monthly Report, September - December 1996.

Resin Key Nuclide Trending Graph (Co-60/Cs-137 ratio) from 10/94 to 12/96.

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RFO 14 Post-outage Radiation Protection Summary.

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, "SCO Application and DAEC," (File 96-10-R).

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Summary of Radioactive Solid Waste, January 1,1995 through December 31,1995.

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. Training Recordr.:

Course 30016, Radwaste Packing and Shipping (1/1/75-2/10/97);

I Course 30045, Radwaste Handling (1/1/75 2/10/97);

Course 60037, Hazardous Material Training (1/1/75-2/10/97);

Course 70001HM125F, HM126F Recertification Training (2/10/95 2/10/97).

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