ML20148P585
| ML20148P585 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/28/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148P541 | List: |
| References | |
| 50-313-97-15, 50-368-97-15, NUDOCS 9707020374 | |
| Download: ML20148P585 (18) | |
See also: IR 05000313/1997015
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Docket Nos.:
50-313
50-368
License Nos.:
NPF-6
Report No.:
50-313/97-15
50-368/97-15
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Units 1 and 2
Location:
Junction of Hwy. 64W and Hwy.333 South
Russellville, Arkansas
Dates:
June 2-6,1997
Inspector:
Michael P. Shannon, Radiation Specialist, Plant Support Branch
Approved By:
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
ATTACHMENT:
Supplemental Information
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9707020374 970620
ADOCK 05000313
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EXECUTIVE SUMMARY
Arkansas Nuclear One, Units 1 and 2
NRC Inspection Report 50-313/97-15;50-368/97-15
Plant beooort
In ganeral, a good external exposure control program was l.1 place. High radiation
areas were properly posted. Radiation work permits were clearly written. Workers
knew the proper response to electronic dosimeter alarms (Section R1.1).
A violation was identified regarding the failure to provide proper access control of a
locked high radiation area (Section R1.1).
Housekeeping throughout the controllod access area was good (Section R1.1).
An internal exposure control program was effectively maintained. Job-specific air
samplers were appropriately placed to assess the airborne concentration levels in
the work area. There was good use of continuous air monitors and high efficiency
particulate air filter ventilation units throughout the controlled access area. The
respiratory program was effectively maintained (Section R1.2).
Outage work planning was effectively implemented. Radiation protection ALARA
personnel were appropriately involved with outage planning. The one-stop shopping
area was a station strength (Section R1.3).
Proper controls were implemented to prevent the spread of radioactive
contamination. Station personnel used the personnel contamination monitors
properly (Section R1.4).
A victation was identified involving the failure to monitor radioactive material
removed from the controlled access area (Section R1.4).
A violation was identified for the failure to determine radiological contamination
conditions in a work area prior to issuing a radiat.m work permit for work in
Unit 2's west deep end refueling canal (Section R1.4).
The licensee implemented an effective ALARA program. The ALARA committee
was appropriately involved and supported by all major station work groups. Shut
down chemistry controls were effective in reducing reactor coolant system activity.
Natural work teams were effective in reducing refueling and steam generator work
activity person-rem exposure. The remote acquisition and display system was a
excellent ALARA tool (Section R1.5).
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Overall, a good contractor training program was in place. Contractor radiation
protection lesson plans were well developed, and included site and industry lessons
learned. Radiation protection management was actively involved in the contractor
radiation protection training program (Section R5.1).
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A very good quality assurance audit sod surveillance program was in place. Audits
and surveillances of radiation protection activities provided appropriate oversight of
radiation protection activities. The 1997 audit and surveillance schedule was
developed with radiation protection management involvement, and covered the
appropriate program areas to provide senior management with a good assessment
of the radiation protection program (Section R7.1).
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REPORT DETAILS,
Summary of Plant Status
Unit 2 was in a refueling outage. Unit 1 operated at full power. No events occurred that
affected the inspection activities.
IV. Plant Support
R1
Radiological Protection and Chemistry Controls
R 1.1
External Exposure Controls
a.
Ir'spection Scope (83750)
Selected radiation workers and radiation protection personnel involved in the
external exposure control program were interviewed. A number of tours of the
radiological controlled area, including Unit 2's reactor building, were performed.
The following items were reviewed:
Radiological controlled area access controls
Control of high radiation areas
Radiation work permits
Job coverage by radiation protection personnel
Housekeeping within the radiological controlled area
Dosimetry use
b.
Observations and Find:nas
in general, high radiation areas were properly . controlled and posted. All Technical
Specification-required areas were locked and properly posted.
However, on Monday, June 2,1997, while touring Unit 2's reactor building,
elevation 335 foot, the inspector observed a radiation protection technician who
was not attentive to his duties. The individual was assigned as a locked high
radiation area door control point monitor for the reactor building sump. The
inspector was able to stand within 2 feet of the individual on all accessible sides,
waving his hands for at least 2 minutes prior to the individual seeing the inspector.
A review of the radiological survey data for the reactor building sump revealed that
the general radiation levels were approximately 25 millirem per hour and did not
meet the Technical Specification requirement for locking. When the inspector
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discussed this point with radiation protection management, the inspector was
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informed that the area was maintained, posted, locked, and controlled as a locked
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high radiation area due to the potential of increased radiation levels. A licensee
review of this incident determined that no unauthorized entries were made in the
reactor building sump during this period.
Technical Specification 6.8.1.a requires, in part, that written procedures be
established, implemented, and maintained covering the activities recommended in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1)
of Appendix A of this regulatory guide includes procedures for access control to
radiation areat. Section 6.6.3 of Procedure OP 1012.017, " Radiological Posting
and Entry / Exit Requirements," Revision 5, states that control points for locked high
radiation areas " ensure only authorized personnel are allowed access to locked high
,
radiation areas." The fact that the individual was not attentive to his duties,
unauthorized personnel could have accessed the locked high radiation area. The
failure to perform duties as required by Station Procedure OP 1012.017 is identified
as a first example of a violation of Technical Specification 6.8.1.a. Appendix A of
Regulatory Guide 1.33, Section 7.e.1 (50-313;-368/9715-01).
Radiation Work Permits were written in a clear consistent manner. The inspector
determined from observations of, and interviews with workers that by dividing the
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radiation work permits into job tasks workers were better able to understand the
radiological conditions and controls, and monitoring requirements used to perform
their assigned task. Additionally, the radiation work permit numbering system,
which used the same number for similar work, with the exception of the year
designator, made it easier to review job history information.
A review of selected radiation work permit packages revealed that, in general,
radiation work permit packages contained the appropriate radiological information in
accordance with management's expectations.
Overall, workers were knowledgeable of the general radiological conditions in their
work area. Workers were questioned on dose rates and contamination levels and
the workers provided proper responses to the inspector's questions. All workers
observed wore their dosimetry properly and knew to leave the work area and
contact radiation protection personnel if their electronic dosimeter alarmed.
Field radiological work briefings performed by radiation protection technicians
provided workers with information on low dose waiting areas.
During toum of the controlled access area, the inspector noted one case in which
a reactor b;ilding radiation protection technician assigned to provide job coverage
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for a num',er of tasks outside the bio-shield, was unaware of the radiological
conditior", and the fact that workers he was responsible for covering, were working
on top ';f the reactor head. The inspector was told by the radiation protection
tM,nician that he had not been informed during a verbal field shift turnover,
approximately 20 minutes earlier, that personnel were working in this area. The
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inspector P o'rmined from interviews with these individuals that they were properly
briefed by
Jation protection personnel and had been working on the reactor head
for appropriately 1 1/2 hours. When this item was discussed with radiation
protection management, they stated that they would review the technician turnover
process.
Housekeeping throughout the controlled access area was good.
c.
Conclusions
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High radiation areas were properly posted. A violation was identified regarding the
failure to provide proper access control of a locked high radiation area. Radiation
work permits were clearly written. Radiation work permit packages contained the
appropriate radiological information. Workers knew the proper response to
electronic dosimeter alarms. Housekeeping throughout the controlled access area
was good.
R1.2 Internal Exposure Controls
a.
Insnection Scope (837501
Selected radiation protection personnel involved with the internal exposure control
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program were interviewed. The following items were reviewed:
Air sampling program, including the use of continuous air monitors and
filtration units
Respiratory protection program
Whole body counting program
The internal dose assessment program
b.
Observations and Findinas
Continuous air monitors were properly used throughout the controlled access area.
High efficiency particulate air filter ventilation units were appropriately used to limit
airborne exposures. Job coverage air samples for radiological work observed was
appropriately placed to assess work area radiological airborne conditions.
Only one task required respiratory equipment for radiological work this outage. The
total effective dose equivalent /as low as is reasonably achievable evaluation
performed for this task to justify respiratory protection use was appropriate.
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As of June 4,1997, there had been two positive whole body counts that occurred
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which exceeded the licensee's action level (10 millirem) for recording internal dose
this outage. The highest dose assigned was 41 millirem. These internal dose
calculations were verified by the inspector to have been performed correctly.
c.
Conclusions
The internal exposure control program was effectively implemented. Job-specific air
samplers were appropriately placed to assess the airborne concentration levels in
the work area. There was good use of continuous air monitors and high efficiency
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particulate air filter ventilation units throughout the controlled access area. The
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respiratory protection program was effectively maintained.
R1.3 Plannina and Preparation
a.
Insoection Scoce (83750)
Radiation protection department personnel involved in radiation protection planning
and preparation were interviewed. The following items were reviewed.
ALARA job planning
ALARA packages
Capture of lessons learned from similar work
Supplies of radiation protection instrumentation, protective clothing, and
consumable items
b.
Observations and Findinas
Radiation protection ALARA personnel were actively involved with the outage
radiologic 0! svork job planning. Tasks were planned well and ALARA work
packages contained both site and industry lessons learned from past similar work
activities.
The licensee established a one-stop shopping area, which kept abreast of the
outage scheduling activities and hold points. The licensee used this area to
coordinate outage work status and resolve discrepancies among departments.
Although a radiation protection representative was not located in the same area as
the one-stop shopping area (due to its close proximity to the radiation protection
supervisor access area) all other major station work groups were assigned to this
area. The inspector noted that the personnel assigned to the one-stop shopping
area were able to obtain updated radiological information and request radiation work
permits without any unnecessary delays. The inspector viewed this practice a
program strength.
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No problems were identified with the adequacy of radiation protection
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instrumentation, protective clothing, and consumable supplies to support outage
radiological work.
The inspector attended a nurnber of radiation protection supervisor and radiation
protection technician shift turnover meetings. Discussions pertaining to work
status, area posting changes, and problems encountered during the shift were
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clearly communicated. Meetings observed by the inspector were performed in a
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professional manner with good open communications among all personnel.
c.
Conclusions
Radiation protection ALARA personnel were effectively involved with outage
planning. Site and industry lessons learned were incorporated in radiological work
packages. The one-stop shopping area was a station strength. Radiation protection
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staff shift turnover meetings were informative.
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R1.4 Control of Radioactive Materials and Contamination: Surveyina and Monitorina
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a.
Insoection Scone (83750)
Areas reviewed included:
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Contamination monitor use and response to alarms
Control of radioactive material
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Portable instrumentation calibration and performance checking programs
Adequacy of the surveys necessary to assess personnel exposure
b.
Observations and Findinas
All personnel observed exiting the controlled access area used the personnel
contamination monitors properly. Radiation protection personnel assigned to
monitor control point activities responded properly to personnel contamination
monitor alarms, and provided proper and timely guidance to station workers who
alarmed the monitors.
Contamination boundaries were clearly marked and posted, step-off pads were
placed at the entrances and exits to contaminated areas. Trash and laundry barrels
were properly maintained to prevent the spread of radioactive contamination. The
inspector observed radiation worker activities, while exiting contaminated areas,
and noted use of good health physics practices.
All radioactive material and high efficiency particulate air filter vacuums observed
were properly labeled and posted.
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During the review of radiological condition reports and radiol
reports written since February 1996, the inspector noted eight
ogical information
which the licensee identified uncontrolled radioactive ma
separate examples in
access area over a 10-month period. One of these items was lab l d
s e the controlled
item was tagged as radioactive materia; indicating th
ee and another
not aware of the release and control requirements of licensed matat some
erial.
In April 1995, the licensee initiated Significant Condition R
identified events involving uncontrolled radioactive materialeport C-95-0084,
corrective actions for the above condition report we
outside the controlled
1995.
ority of
y the end of
Technical Specification 6.8.1.a requires, in part that writt
established, implemented, and maintained covering the activities
en procedures be
,
Appendix A ni Regulatory Guide 1.33, Revision 2 February 1978
recommended in
of Appendix A of this regulatory guide addresses procedures for
. Section 7.e(4)
,
Entry / Exit Requirements," Revision 5, requires, in pa
contamination
osting and
carried items are required to be monitored for release prior to reequipment an
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controlled access area.
moving from a
The failure to monitor radioactive materialis a violation of T
Specification 6.8.1 (50-313;-368/9715-02).
echnical
determined that these items did not meet the criteria for
on, the inspector
described in Section Vll.B.1 of the NRC Enforcement P li
xercise of discretion, as
o cy.
All portable radiation protection survey instrumentation wa
response checked in accordance with radiation protection proceds calibrated an
ures,
independent radiological survey measurements performed b
tours of the controlled access area confirmed that radi l
y the inspector during
compliance with regulatory requirements.
o ogical postings were in
Surveys, including area posted survey maps, were docum
consistent manner.
ented in a clear and
On Thursday, June 5,1997, the inspector identified that p
west deep end refueling canal were not informed of the extent of thersonnel
conditions in their work area. The work crew interviewed in
e contamination
hey were entering a posted high contamination area; however the
e
new that
y were not
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aware of the actual contamination conditions. In discussions with the night shift
radiation protection supervisor, the inspector was informed that the area had always
been controlled as a high contamination area and that a bag which contained
smears taken on May 31,1997, from around the shallow portion (reactor flange
area) of the refueling cavity was reading 500 mrad per hour.
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A review of the Radiation Work Permit 2-1997-2021, Task 7, revealed that
contamination levels were written as "N/A" (not available). The radiation work
permit package did not contain a contamination survey of the work area. A review
of the prejob briefing sheet for the above task revealed that it did not discuss the
work area contamination level.
A survey performed during work in the area documented that the contamination
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levels ra3 'd from 120 mrad per hour to as high as 300 mrad per hour.
Additionahy the inspector noted that the work performed (engineering
measurements) in the area created an airborne condition (1.37 derived air
concentration). A review of the personnel contamination event log revealed that no
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contamination events occurred during this task.
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Later the same day, the radiation protection manager provided the inspector with a
copy of a contamination survey, which was performed in the west deep end
refueling canal on Wednesday, June 4,1997. A review of this survey showed that
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contamination levels in the work area we.,re as high as 4.4 Rad per hour. This
survey was found in another radiation work permit task package and was not used
by the night shift radiation protection supervisor to brief the workers on the
contamination levels in their work area or determine if appropriate radiation work
permit radiological requirements were in place prior to the workers entering the
area.
Technical Specification 6.8.1.a requires, in part, that written procedures be
established, implemented, and maintained covering the activities recommended in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1)
of Appendix A of this regulatory guide includes procedures for the radiation work
permit system. Section 6.2.1 of Procedure OP1012.019, " Radiation Work
Permits," Revision 5, states, in part, "When the need for an RWP is identified,
determine the followirg: (A) Radiological conditions for the proposed worn area
using either live time information or routine survey data, (B) Historical radiological
conditions for the proposed work area."
The failure to determine the radiological contamination conditions for work in
the west deep end cavity using eithe'r live time information or routine survey data,
and historical radiological conditions for the this area, prior to the work crew
entering the area is identified as a second example of a violation of Technical Specification 6.8.1.a., Appendix A of Regulatory Guide 1.33, Section 7.e.1
(50-313/-368/9715-01).
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During the review of radiological condition reports and radiological information
reports written since February 1996, the inspector noted eight separate examples in
which the licensee identified uncontrolled radioactive material outside the controlled
access area over a 10-month period. One of these items was labeled and another
item was tagged as radioactive materialindicating that some station workers were
not aware of the release and control requirements of licensed material.
In April 1995, the licensee initiated Significant Condition Report C-95-0084, which
identified events involving uncontrolled radioactive material outside the controlled
access area as far back as 1993. The inspector noted that the majority of
corrective actions for the above condition report were completed by the end of
1995.
Technical Specification 6.8.1.a requires, in part, that written procedures be
established, implemented, and maintained covering the activities recommended in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(4)
of Appendix A of this regulatory guide addresses procedures for contamination
control. Section 6.12.5 of Procedure OP1012.017, " Radiological Posting and
Entry / Exit Requirements," Revision 5, requires, in part, that all equipment and hand
carried items are required to be monitored for release prior to removing from a
controlled access area.
The failure to monitor radioactive materialis a violation of Technical Specification 6.8.1 (50-313;-368/9715-02). Because effective corrective actions
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were not implemented after the licensee identified the first violation, the inspector
determined that these items did not meet the criteria for exercise of discretion, as
described in Section Vll.B.1 of the NRC Enforcement Policy.
All portable radiation protection survey instrumentation was calibrated and source
response checked in accordance with radiation protection procedures.
!
Independent radiological survey measurements performed by the inspector during
!
tours of the controlled access area confirmed that radiological postings were in
compliance with regulatory requirements.
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Surveys, including area posted survey maps, were documented in a clear and
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consistent manner.
]
On Thursday, June 5,1997, the inspector identified that personnel entering Unit 2's
west deep end refueling canal were not informed of the extent of the contamination
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conditions in their work area. The work crew interviewed in the field knew that
j
they were entering a posted high contamination area; however, they were not
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aware of the actual contamination conditions. In discussions with the night shift
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radiation protection supervisor, the inspector was informed that the area had always
been controlled as a high contamination area and that a bag which contained
smears taken on May 31,1997, from around the shallow pcetien (reactor flange
area) of the refueling cavity was reading 500 mrad per hour.
l
A review of the Radiation Work Permit 2-1997-2021, Task 7, revealed that
,
contamination levels were written as "N/A" (not available). The radiation work
l
permit package did not contain a contamination survey of the work area. A review
of the prejob briefing sheet for the above task revealed that it did not discuss the
work area contamination levels.
A survey performed during work in the area documented that the coritamination
levels ranged from 120 mrad per hour to as high as 300 mrad per hour.
Additionally, the inspector noted that the work performed (engineering
measurements) in the area created an airborne :ondition (1.37 derived a:r
concentration). A review of the personnel contamination event log revealed tha lo
contamination events occurred during this task.
Later the same day, the radiation protection manager provided the inspectcu with a
copy of a contamination survey, which was performed in the west dsep end
refueling canal on Wednesday, June 4,1997. A review of this survey showed that
,
'
contamination levels in the work area were as high as 4.4 Rad per hour. This
survey was found in another radiation work permit task package and was not used
by the night shift radiation protection supervisor to brief the workers on the
contamination levels in their work area or determine if appropriate radiation work
permit radiological requirements were in place prior to the workers entering the
area.
Technical Specification 6.8.1.a requires, in part, that written procedures be
established, implemented, and maintained covering the activities recommended in
Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Sectbn 7.e(1)
of Appendix A of this regulatory guide includes procedures for the radia on work
permit system. Section 6.2.1 of Procedure OP1012.019, " Radiation Work
Permits," Revision 5, states, in part, "When the need for an RWP is identified,
determine the following: (A) Hadiological conditions for the proposed work area
using either live time information or routine survey data, (B) Historical radiological
conditions for the proposed work area."
The failure to determine the radiological contamination conditions for work in
^
the west deep end cavity using either live time information or routine survey data,
and historical radiological conditions for the this area, prior to the work crew
i
entering the area is identified as a second example of a violation of Technical
(
Specification 6.8.1.a., Appendix A of Regulatory Guide 1.33, Section 7.e.1
(50-313/-368/9715-01).
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c.
Conclusions
Station personnel used the personnel contamination monitors properly. Radioactive
material was properly posted and labeled. Good controls to prevent the spread of
contamination were maintained. A violation was identified involving the failure to
ontrol radioactive material outside the controlled access area. Radiation protection
portable survey instrumentation was properly calibrated and source response
checked. A violation was identified for the failure to determine radiological
contamination conditions in a work area prior to the start of work.
R1.5 Maintainina Occupational Exoosure As Low As is Reasonablv Acnievable (ALARA)
a.
insoection Scope (83750)
Radiation protection personnel involved with the ALARA program were interviewed.
The following areas were reviewed:
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ALARA committee support
Exposure goal establishment and status
Hot spot reduction and temporary shielding programs
Lesson learned capture
ALARA suggestion programs
b.
Observations and Findinas
Shutdown chemistry controls were effective in reducing reactor coolant system
activity. Dose rates were reduced approximately 20 percent from the previous
Unit 2 refueling outage. The inspector noted good use of tele-dosimetry to monitor
reactor coolant system activity during the shutdown.
A review of the ALARA committee meeting minutes showed that the ALARA
committee was appropriately involved in station goal setting and monitoring. All
major work groups provided good station support to the committee.
The licensee developed " Natural Work Teams," which consisted of first-line
supervision, system engineers, and craft level personnel for work involving refueling
and steam generator activities. Some of the duties of these teams were to
coordinate their tasks with the station schedule and improve ALARA work practices
for their tasks. A review of the accumulated exposures for these tasks revealed
that both tasks were completed with less exposure than any past performances of
these activities at the station. Refueling exposure activities were approximately
11 person rem verses a previous best of 14 person-rem, and steam generator work
was completed in just over 24 person-rem verses a previous best of 35 person-rem.
The inspector determined that the use of " Natural Work Teams" was a program
strength.
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Station, department, and individual radiation work permit exposures were
appropriately tracked and trended by the ALARA group. Station exposure goals
were aggressive and set based on past best performance and industry experience.
The Unit 2 refueling outage goal of 110 person-rem was the lowest in the history of
the station. A review of the actual exposure to date, verses the remaining work,
indicated that it was likely that the licensee could come under 100 person-rem for
the refueling outage.
A good temporary shielding program was in place. There were 77 temporary
shielding packages installed this refueling outage, with a projected dose savings of
aporoximately 10 person-rem. A random review of the temporary shielding
pa kages revealed that they were in a neat orderly manner, and engineering
evaluations were performed as appropriate.
The hot spot reduction program had been effectively implemented, and operations
personnel were appropriately involved. On January 1,1997, there were 48 hot
spots throughout the :or. trolled access area, as of June 4,1997,38 hot spots
remain.
During tours of the controlled access area, the inspector noted that ALARA "do not
loiter" flashing signs were used throughout the auxiliary and fuel storage buildings
to identify areas of higher radiation levels; however, the inspector did not find the
use of these signs in the reactor building. The inspector commented that the use of
ALARA "do not loiter" signs in the reactor building could reduce personnel
exposures. The licensee stated that they would evaluate the inspector's comment
for future use.
The licenseo recently established an extensive remote job coverage and area
radiologicci monitoring system called remote acquisition and display system.
This system was used for high dose work, such as primary side steam generator
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work. Additionally, general reactor building area radiation and airborne
concentration levels were monitored with this system. This system allowed
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radiation protection job coverage and area monitoring from outside the controlled
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access area by using tele-dosimetry, wireless remote radiation survey
'
instrumentation and continuous air monitors, cameras, and radio communications.
The licensee conservatively estimated a dose savings to station workers, which
included radiation protection personnel, of 10 person-rem. The acquisition of this
system showed strong management support of the ALARA program.
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c.
Conclusions
The ti.censee implemented an effective ALARA program. The ALARA committee
was appropriately involved and supported by all major station work groups.
Shutdown chemistry controls were effective in reducing reactor coolant system
i
activity. Aggressive exposure goals were set based on best past performance,
j
Natural work teams were effective in reducing refueling and steam generator work
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Station, department, and indivi(Nat radiation work permit expcsures were
appropriately tracked and trendet, by the ALARA group. Station exposure goals
were aggressive and set based on oest best performance and industry experience.
The Unit 2 refueling outage goal of 110 person-rem was the lowest in the history of
the station. A review of the actual exposure to date, verses the remaining work,
indicated that it was likely that the licensee could come under 100 person-rem for
the refueling outage.
A good temporary shielding program was in place. There were 77 temporary
,
shielding packages installed this refueling outage, with a projected dose savings of
.
approximately 10 person-rem. A random review of the temporary shielding
1
4
packages revealed that they were in a neat orderly manner, and engineering
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{
evaluations were performed as appropriate.
The hot spot reduction program had been effectively implemented, and operations
"
personnel were appropriately involved. On January 1,1997, there were 48 hot
spots throughout the controlled access area, as of June 4,1997,38 hot spots
'
remain.
1-
During tours of the controlled access area, the inspector noted that ALARA "do not
loiter" flashing signs were used throughout the auxiliary and fuel storage buildings
,
'
to identify areas of higher radiation levels; however, the inspector did not find the
use of these signs in the reactor building. The inspector commented that the use of
ALARA "do not loiter" signs in the reactor building could reduce personnel
exposures. The licensee stated that they would evaluate the inspector's comment
,
i
for future use.
The licensee recently established an extensive remote job coverage and area
radiological monitoring system called remote acquisition and display system.
- ,
This system was used for high dose work, such as primary side steam generator
work. Additionally, general reactor building area radiation and airborne
concentration levels were monitored with this system. This system allowed
J
radiation protection job coverage and area monitoring from outside the controlled
access area by using tele-dosimetry, wireter:s remote radiation survey
instrumentation and continuous air monitors, cameras, and radio communications.
The licensee conservatively estimated a dose savings to station workers, which
included radiation protection personnel, of 10 person-rem. The acquisition of this
system showed strong management support of the ALARA program.
c.
Conclusions
The licensee implemented an effective ALARA program. The ALARA committee
l
was appropriately involved and supported by all major station work groups.
Shutdown chemistry controls were effective in reducing reactor coolant system
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activity. Aggressive exposure goals were set based on best past performance.
Natural work teams were effective in reducing refueling and steam generator work
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activity person-rem exposure. Good temporary shielding and hot spot reduction
programs were in place. ALARA "do not loiter" signs were effectively used in the
auxiliary and fuel storage building, but were not used in the reactor building. The
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remote acquisition and display system was a excellent ALARA tool.
R5
Staff Training and Qualification in Radiological Protection and Chemistry
R 5.1
Radiation Protection Staff Trainino
a.
Insoection Scone (83750)
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Personnel involved with contractor radiation protection technician training, and
resume evaluation were interviewed. The following items were reviewed:
Radiation protection instructor qualifications
Contractor radiation protection technician training lesson plans
On-the-job training and evaluation programs
Resumes of contractor radiation protection technicians
a
Radiation protection management oversight of the training program
e
b.
Observations and Findinas
i
A review of the radiation protection instructors' qualifications revealed that all the
instructors l - a number of years of operational radiation protection experience and
were well quahtied for their positions.
Twenty-six senior radiation protection contractor technicians were hired to support
outage activities. A review of the resumes indicated that about 60 percent were
returnees and 25 of the 26 met or exceeded the requirements of an American
Nuclear Standards institute 3.1 (3 years of radiation protection experience) level
technician, where as the licensee's Technical Specifications only required a ANSI
18.1Property "ANSI code" (as page type) with input value "ANSI</br></br>18.1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (2 years of radiation protection technician experience) level technician.
Contractor radiation protection lesson plans were well developed, included site and
industry lessons learned. Radiation protection management was appropriately
involved in developing the topics and monitoring the training program.
The Northeast Utilities' radiation protection screening program was used to evaluate
the general technical radiological knowledge of the contract radiation protection
technicians brought onsite to support outage activities. The Northeast Utilities
program is recognized and approved by a number of utilities as an a ceptable
method to evaluate a radiation protection technician's general technical radiological
knowledge. All contractor radiation protection technicians were required to have
passed this screening examination within the last 5 years, prior to being placed in
the licensee's site-specific training prograrn.
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~ All contractor radiation protection technicians were tested on site-specific-
information, and on-the-job evaluations were given and tracked by radiation
I
protection station personnel.
Radiation protection management was appropriately involved in the on-the-job
evaluation program. Tasks listed were appropriate for outage assigned duties and
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evaluation guidelines were clearly written. ' Additionally, once a contractor radiation
protection technician completed the on-the-job evaluation program, radiation
protection supervision interviewed these technicians to ensure their understanding
of the program requirements.
c.
Conclusions
Overall, a good contractor training program was in place. Radiation protection
instructors were well qualified to perform their duties. Contractor radiation
protection lesson plans were well developed, and included site and industry lessons
learned. Radiation protection management was actively involved in the contractor
,
radiation protection training program.
)
R6
Radiological Protection and Chemistry Organization and Administration
' The inspector reviewed the present organization chart and compared it to an
organization chart obtained during the previous inspection. No major changes were .
identified. The licensee's organizational structure for implementing the radiation
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protection responsibilities had a clear delineation of authority and responsibility.
The licensee maintained an appropriate organization to effectively implement the
radiation protection progic. .
R7
Quality Assurance in Radiological Protection and Chemistry Activities
R7.1 Quality Assurance Audits and Surveillances, and Radiation Department Self
J
Assessments and Radioloaical Occurrence Reoorts
a.
Insoection Scope (83750)
Selected personnel involved with the performance of quality assurance audits and
. surveillances, and radiation department self-assessments were interviewed. The
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following items were reviewed:
Quality assurance audits performed since February 1,1996
Quality assurance surveillances performed since February 1,1996
Radiation protection department self assessments performed since
February 1,' 1996
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Radiological condition reports and radiological information reports written
since February 1,1996
b.
Observations and Findinas
Two radiological audits and four radiological surveillances were performed since
February 1996. Technical specialists from other sites were used to support the
licensee's staff in the performance of the 1997 audit. The surveillances conducted
by quality assurance personnel covered a broad range of subject arees The audits
and surveillances performed provided management with a good assessment of the
radiation protection program.
Radiation Protection Audit QAP 3-97, " Health Physics," conducted from February 4
through March 20,1997, identified five findings and nine recommendations. The
findings were documented in condition reports. All findings and recommendations
were closed out in a timely manner and corrective actions appeared to be effective
to prevent a similar occurrence. The audit was comprehensive and covered the
major aspects of the radiation protection program.
No problems were identified during the review of the audit and surveillance schedule
and plans pertaining to the radiation protection program. Radiation protection
management and quality assurance management were appropriately involved in the
development of the audit and surveillance plans.
One radiation protection department self assessment was performed since the last
inspection of this area. The self assessment was self critical and provided
i
management with a good overview of the radiation protection program.
The licensee's corrective action program consisted of the condition reporting system
and the radiological information reporting system. The condition reporting system
was an upper level system used by the station to report and track significant
station-wide issues of all types. The radiological information reporting system was
1
used to track and trend less significant radiological issues.
Selected examples of both reporting systems were reviewed. The inspector
determined that the licensee's threshold for documenting events was proper.
During the review, the inspector identified that the control of radioactive material
q
,
was a continuing problem, as described in Section R1.4. Additionally, the control of
high radiation area boundaries had been a problem in the past; however, recent
'
corrective actions appeared to have resolved this problem.
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c.
Conclusions
- Audits and surveillances of radiation protection activities performed by quality
assurance personnel provided appropriate oversight of radiation protect!on activities.
The 1997 audit and surveillance schedule was developed with radiation protection
[
management involvement, and covered the appropriate program areas to provide
senior management with a good assessment of the radiation protection program.
A good corrective action program was in place to address audit and surveillance
findings.
V. Manaaement Meetinas
X1
Exit Meeting Summary
The inspector presented the inspection results to members of licensee management
at an exit meeting on June 6,1997. The licensee acknowledged the findings
presented. No proprietary information was identified.
/
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTAC' ED
Licensee
R. Edington, General Manager
C. Anderson, Unit 1 Plant Manager
G. Ashley, Licensing Supervisor
B. Bement, Radiation Protection / Chemistry Manager
T. Chilcoat, Senior Oversight Specialist, Corporate
C. Fite, In House Events Supervisor
R. Lane, Design Engineering Director
B. McKervy, Chemistry Superintendent
J. Sraith, Radiation Protection Superintendent
D. Wagner, Quality Assurance Supervisor
NRC
K. Kennedy, Senior Resident inspector
INSPECTION PROCEDURE USED
83750
Occupational Radiation Exposure
'
LIST OF ITEMS OPENED AND CLOSED
Opened
50-313;-368/9715-01
Failure to follow radiation work permit requirements and
,
locked high radiation control point duties.
50-313;-368/9715-02
Failure to maintain control of radioactive material
outside the controlled access area.
LIST OF DOCUMENTS REVIEWED
Quality Assurance Procedure QAP-3, " Health Physics," Revision 11
Quality Assurance Procedure QAO-6, " Internal Audits," Revision 14
Radiation Protection Procedure OP-1012.002, " Contract HP Technician Selection &
Qualification," Revision 2
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Radiation Protection Procedure OP-1012.017, " Radiological Posting and Entry / Exit
Requirements," Revision 5
Radiation Protection Procedure OP-1012.019, " Radiological Work Permits," Revision 5
Radiation Protection Procedure OP-1012.020, " Rad Material Control," Revision 4
Radiation Protection Procedure OP-1012.027, "ALARA Program," Revision 2
Radiation Protection Procedure OP-1601.003, " Control of Temporary Shielding," Revision 4
Radiation Protection Procedure OP-1601.301, " Radiological Survey," Revision 5
Contractor Health Physics Training Program, ANO-S-LP-HPCR-42201, Revision 14
ALARA Committee Meeting Minutes Numbers: ANO-96-00273; ANO-96-00562;
ANO-96-00823; ANO-96-00869; ANO-96-00995; and ANO-97-00294
A summary of radiological condition and ir: formation reports written between February 1,
1996, and June 1,1997
Corporate Radioactive Material Assessment dated December 6,1996
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Quality Assurance Audit Report QAP-3-96, " Health Physics"
Quality Assurance Audit Report QAP 3-97, " Health Physics"
Quality Assurance Surveillance Reports: SR 010-96; SR 015-96; SR 021-96; and
SR 023-96