ML20196J145
| ML20196J145 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/04/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| 50-313-98-15, 50-368-98-15, NUDOCS 9812090268 | |
| Download: ML20196J145 (4) | |
See also: IR 05000313/1998015
Text
{{#Wiki_filter:.. .- . _ . .. _- . - .- - _ - - . . . On% 9'og UNITED STATES E NUCLEAR REGULATORY COMMISSION o $ j REGION IV o g 611 RYAN PLAZA DRIVE. sulTE 400 gg*****,o D ARUNGToN. TEXAS 76011-8064 December 4, 1998 ) C. Randy Hutchinson, Vice President Operations Arkansas Nuclear One
Entergy Operations, Inc. 1448 S.R. 333 Russellville, Arkansas 72801-0967 SUBJECT: NRC INSPECTION REPORT 50-313; 368/98-15 . Thank you for your letter of November 9,1998, in response to the exercise weakness identified in NRC Inspection Report 50-313; 368/98-15, as modified by our October 9,1998, letter. We have reviewed your reply and find it responsive to the concerns raised in our i inspection report. We will review the implementation of your corrective actions during a future . inspection. i ' Sincerely, c ( W Blaine Murray, Ch of Plant Support Branch Division of Reactor Safety Docket Nos.: 50-313 50-368 License Nos.: DPR-51 NPF-6 l cc: Executive Vice President & Chief Operating Officer i Entergy Operations, Inc. i P.O. Box 31995 Jackson, Mississippi 39286-1995
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. Entergy Operations, Inc. -2- Vice President Operations Support Entergy Operations, Inc. P.O. Box 31995 Jackson, Mississippi 39286 Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & Strawn 1400 L Street, N.W. Washington, D.C. 20005-3502 David D. Snellings, Jr., Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Mail Slot 30 Little Rock, Arkansas 72205-3867 Manager Rockville Nuclear Licensing Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852
. . Entergy Operations, Inc. -3- DISTRIBUTION w/ copy of letters dated October 9 and November 9.1998: bec to DCD (IE35) Regional Administrator ANO Resident inspector i DRS Director DRS Deputy Director DRP Director Branch Chief (DRP/C) Project Engineer (DRP/C) DRS-PSB Branch Chief (DRP/TSS) RIV File MIS System
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12/LY98 12D/98 \\ OFFICIAL RECORD COPY
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DOCUMENT NAME: R:\\_ANO\\AN815AK.GMG ' To receive copy of document, Indicete in box: "C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy RIV:PSB E C:DRS\\PSR l l l { GMGood:nh (W BMurray D
12/W98 12h/98
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-9bx -p ) y$ hn sobf ' c C \\' / C. Randy Hutchinson, Vice President ' g . Operations 4[Sj ' - Arkansas Nuclear One -- Entergy Operations, Inc. ' 1448 S.R. 333 / Russellville, Arkansas 72801-0967 SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-313; 368/98-15 Dear Mr. Hutchinson: l The purpose of this letter is to inform you of a change in the characterization of an issue - discussed in NRC Inspection Report 50-313; 368/98-15, dated September 2,1998. The report ' identified an exercise weakness for failure to complete initial accountability within 30 minutes of , l the site area emergency declaration (50-313; 368/9815.-01). During a September 22,1998, conference call, your staff provided additionalinformation concerning this issue. As a result, we have decided to refer the issue to the Office of Nuclear Reactor Regulation (NRR) for resolution. Accordingly, the issue will be tracked as an unresolved item, rather than an inspection followup item, pending comp!etion of NRR's review. On September 24,1998, an extension to the response time for both exercise weaknesses was granted so that we could review the additional information concerning the accountability issue. Since characterization of that issue has changed, a response to 50-313; 368/9815-01 is not necessary at this time. We will be in contact with you later regarding the dispositioning of this matter. j Please proceed with the response to the exercise weakness concerning the failure to implement proper radiological protection practices. We request a response within 14 days of the date of this letter. ' , l in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room. I t ! t- , ! l iNIOLMooM W 6 [ /
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Entergy Operations, Inc. -2- , , Should you have any questions concerning this letter or the inspection, we will be pleased to discuss them with you. Sincerely, ! Blaine Murray, Chief Plant Support Branch , ' Division of Reactor Safety Docket Nos.: 50-313 50-368 License Nos.: DPR-51 l NPF-6 cc: Executive Vice President , l & Chief Operating Officer - . Entergy Operations, Inc. ' P.O. Box 31995 l - Jackson, Mississippi 39286-1995
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Vice President l Operations Support Entergy Operations, Inc. P.O. Box 31995 l Jackson, Mississippi 39286 f Manager, Washington Nuclear Operations l ABB Combustion Engineering Nuclear Power t , ' l- 12300 Twinbrook Parkway, Suite 330 l Rockville, Maryland 20852 l County Judge of Pope County Pope County Courthouse . Russellville, Arkansas 72801 Winston & Strawn - 1400 L Street, N.W. j Washington, D.C. 20005-3502 . 4 $ , 4 J I , w , - , . , .,- , ,, -- ,.
- ._ __ _.- _.-.._. ..__ _..... _ ._._._____ _ _ . _ . - _ _ . . _ _ _ . _ . - . ._ i - , . - l .- \\. Enter 9yOperations, Inc. ! David D. Snellings, Jr., Director \\ l Division of Radiation controland Emergency Management Arkansas Department of Health Little Rock, Arkansas 4815 Wast Markham Street MailSl ' , o. 72205-3867 Manager Framatoma TechnologiesRockville Nuclear Licen 1 ' Rockville, Maryland 208521700 Rockville Pike, Su , .. - +h , I- 1 i -' s . l u < , \\ u k ,- ! , I l- l [~ ! { ! , . . . . _ , _ - - , . ._ ,m.. ., - - , . -
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O Entergy Opered3ns,Inc. 1445 SA 333 RusseMs. AR 72801 Tel 501858-f400 10 CFR Part 50, Appendix E.IV.F.2.g November 9,1998 ~ OCAN119804 - -' 't " U. S. Nuclear Regulatory Commission Document ControlDesk Mail Station OPI-17 Washington, DC 20555 Subject: Arkansas Nuclear One-Units 1 and 2 Dockets Nos. 50 313 and 50 368 LicenseNos. DPR-51 and NPF-6 Respor.ae To Inspection Report 50-313/98-15; 50 368/08-15 Gentlemen: Entergy Operations has reviewed your cotTespondence dated September 2,1998 (OCNA099801) and October 9,1998 (OCNA109810) regarding the inspection of activities associated with the Arkansas Nuclear One (ANO) emergency preparedness pmgnm. The correspondence dated October 9,1998 docilmented the change in characterization of one issue and established a new , response date of October 23,1998. However, the October 9,1998 correspondence was not j received by ANO until October 26,1998, and on that day, a new due date of November 9,1998 , was verbally established by Ms. Gail Good of the Region IV stafE g Attached is our analysis of the weakness identified concerning the failure to implement proper radiological protection pmctices. Should you have any questions or comments, please contact me at (501) 858-4601. i ' Very truly yours, . Ji my D. Vand 'ft Director, Nuclear Safety JDV/SLP Attachment ' - . , h[[- I
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. DEC-03-il 18:00 From:ANO G$B 1 5818584685 T-204 P.03/87 Job-958 . . ~
U. S. NRC November 9,1998 OCAN119804 Page 2 cc: Mr. Ellis W. Merschoff Regional Administrator U. S. Nuclear Regulatory Commission RegionIV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC SeniorResidentInspector Arkansas Nuclear One P. O. Box 310 London, AR72847 . . _ _ , Mr.NickHilton - e' > 't NRRPfoject ManagerRegionIV/ANO-1 U. S. NuclearRegulatory Commission NRRMail Stop 13-H 3 One White Flint North 11555 RockvillePike Rockville, MD 20852 Mr. Chris Nolan NRKProject Manager RegionIV/ANO-2 U. S. Nuclear Regulatory Commission NRRMail Stop 13-H-3 One WhiteFlint North 11555 Rockville Pike Rockville,MD 20852 i e a h
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Attachment to 0CAN119804 Page1of4 Weakness: i l The failure to implement proper radiological protection practices was identified as an exercise weakness (50-313; 50-368/98015-02). ' .. ..% Description of Conditless and Corroetive Actions: The examples of improper radiological protection practices that were identified, along
with ANO's evaluations, are as follows: i The healthphysics supervisor did not enter estimatedwork area dose rates, estimated e work arwa derind air concentratums, and'or estimated work area contamination Jewis on 16 of24 OSC Team Brie)frggFanns (1903.033B). i The OSC Team Briefing form is used to document briefings conducted prior to re- ) entering the plant. The form is a tool used by the radiation protection (RP) ' j supervisors to ensure all areas of radiological control are addressed in the briefings. Deficiencies currently exist in the format of the form with respect to the estimated work area dose rate, the estimate work area derived air concentrations (DACs), and'
the estimated work area contamination level sectens. These format deficiencies coincide whh the majority of the errors made regarding incomplete briefing forms. Additionally, other key information required to be included in briefings was not included on the form. l _ Radiological surveys were used during team briefings to discuss radiological i conditions; however, these surveys were not attached to the briefing forms. ! 'Ihis weakness concerning incomplete OSC Team Briefing Forms was reviewed with ' the involved RP supervisors. This weakness was also reviewed with emergency response organization (ERO) teams during drills conducted in the OSC on October 6, October 27, and November 3,1998. Revisions to this form by March 31,1999, are l planned to address items such as format consistency, radiological release information, separation requiremente, administrative dose rate call back information, and ALARA. Although the majority of oluerved radological briefngs provided repair teams with
proper raiologicalirstbrmation andcoreols needed 10 couplete assigned tasks in a l radologically safe manner, some briefrugs were not thorough. For example, Team 23 l (assigned to check the electromatic relief valw .nvitch on Panel C47 in the auxiliary - buil6ng) mas nor informed of the -~7% nauarion, airborne, and contamination Jewisin the assignedworkarwa. The form format deficiencies referenced above contributed to the briefing deficiencies. ! ! . '
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,t(C-02-98 18:01 From:20 SSB 1 5018584t85 V-304 P.05/07 Job-950 .. l Attachment to
l OCAN119804 Page 2 of 4 1 ' i - 'Ihis example ofincomplete OSC Team Briefing Forms was also reviewed with the { involved RP supervisors and with ERO teams during OSC drills. The revisions i planned for the OSC Team Briefing Form discussed above will also address this i weakness. l i lhe rahation protection technician assigned to Team 9 allowed the team to become e j separated nro mechanicalmaintenance workers were allowed to travel between the mainknonce . shop area and thejob site without radiation protection personnel, enn ' though a nicase was in progress. A post.eurcise interview revealed that the i
ra6ation protection kehnicias mar not aware that a nioax was in progress. Although the health physics supervisor briefed the team on espected radiation and } ccatamination lewis in the work area, the team was not irgformed that a release was
inprogre.tr. 1 l Procedure 1903.033, Prvrectin Action Guidelinesfor Re.wwe/ Repair amiDamage . j Contact Teams, section 6.2.3.C states, " Rescue / repair and damage control teams shall i be accompanied by a member of the Emergency Radiation Team during initial entry 1 and subsequent re-entries into the plant areas until radiation etess have been marked." l The team should not have separated prior to returning to the OSC. i l This weakness concerning team separation was reviewed with the RP technician l assigned to team 9 during the exercise. Additionally, procedural compliance '
expectations during emergency response evolutions will be discussed with RP
personnel by January 31,1999. i ! Electronic dosimeter (ED) settings did not accurately reflect expected radiation work e
area dose rates. All electronic dosimeter alem settings were 4,000 millirem
integrated dose and .50,000 millirem per hour dose rate, regardless of espected i general area radiation dase rates madprojected time at thejob site.1he general area ruaation dox ruksfor workperformed durtrng this exercise rangedfrom less than 1 millirem to as high at 100 millirems. The impectors concluded that setting the electrordc dasimeters at levels greatly above the expected area radiation levels were not npresentatin ofactual radiation Jewis. The radiological work permit (RWP) Writer's Guide outlines an alarming dosimeter setpoint process based on area dose rates and time. During an emergency, area dose rates can change rapidly. Emergency re-entry team alarming dosimeters have been set at upper thresholds to reduce team return Requency based on changing dose rates and low ED alarm settings. However, the alarm settings still provide a level of protection. Briefings with team members establish administrative dose rate call back levels without risking worker ED alarms and unnecessary return for alarm setting incrosses. Valuable time can be lost and extra team dose received as a result of restrictive ED settings and area dose rate changes. ' --
_ _ _. _ _ _ __ - _ - -_. - __ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ __ ' DEC-03-98 18:01 From:ANO$$s1 5018584E85 T-304 P.06/07 Job-350 . . Attachment to OCAN119804 Page 3 of4 ' _ . . Ahhough' setting ED alarms at an upper threshold has been standard practice, an efrott to enhance the tue of EDs during emergencies will be conducted. A mannaeable emergency entry ED alarm setpoint process that better represents PM area dose rates will be developed by March 31,1999. i < Repair seams wra not ginn rabologicallewilimits to he{p the radiattnn protection e ucinucian know when to exit the era or cornact rasationprotection supervisionfor aai6tionaldrectiorarAnstrucdons. Repair team members were briefed on radiological conditions and requirements; l however, these briefings were not consistent or properly documented. The form format deficiencies referenced above contributed to some of these briefing ' deficiencies. ] ' The revisions to the OSC Team Briefing Forms discussed above will address this weakness. Radological surnysper)brasd were not represenhatin'of radological comittions in
the work area. At about 10 a.m., Teams 1 mai2 obtained an air sample at the)>isking area of the turbine bullung train bay, raner than ne "bowlig alley" arwa of the \\ turbine buildry where the leak was located A representatke general work area ' sample was not taken smtil about 11:35 a.m., 30 minutes qfter Team'9 entered the , orea no innstigate med)fe Ae source ofthe leal \\ Interviews with the two RP technicians (Teams I and 2) involved determined that they were dispatched from the OSC to perform initial surveys of the Unit I turb'me building (bowling alley) area. While one RP technician performed an air semple in the train bay area the other surveyed the immediate area of the leak (including an air sample). Teans 1 and 2, which consisted qf only radadon protection personnel, dd nor best
properly to enter a potentially w ^^^*=' area of the Unit 1 turbine buildig 'bowlim alley" (known to haw water an the floor). Both maation protection s techm1cians wore latee glows andplaced aplastic beg on eachfoot, instead ofrubber boortes and shoe cowrs. Conraits were not dmned The glows and begs were not . checkedfor holes and narsprior to danniq. In adhtion, one sean member remond a glow and trauferred a portable surwy instrument between the glowd and uniond harad numerous times before exitig the area. Since significant contaminaden lewis wre present (60,000 &m/100cm"), the portable surwy tnstrument waspotenstally contantnated . This is an example of i=d-ste worlt practices and unclear management i expectations. In some instances, emergency team members believed.they had the option to exercise actions outside of nonnal radiological protection practices to l ' . r w - r- -. ,-w w - -- g v
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DEC-03-88 18:02 From:ANO GSB 1 SD18584685 ?-204 P.0F/07 kb-950 . Ae+a===* to j OCAN119804
Page 4 of 4 reduce response time. RP technicians are expected to follow procedure and ! understand the requirements for catry into potentially contaminated areas. ! A site-wide radworker campaign (including antic clothing inspections) will be > implemented prior to January 31, 1999. Additionally, procedural complience
expectations during emergency response evolutions will be discussed with RP ' personnel by January 31,1999. f No one on Team 9 (foer member.s includirqr me ndatim protectim techniciat) e i checkedpmtective cloddeprior to &wssim ne team mu sent w the %wlin j alley" area to identfy andjix the source ofthe leak This is another example.of inadequate work practices and unclear management l i .
A is. Inspectmg for lips and tears in anti-c clothing is expected of all
radworkers In the haste of preparing for an emergency entry the team did not
perform an adequate inspection of their anti-c clothing. The team may havs noticed large tears and holes during dressing but smaller flaws could have been overlooked ' without a meticulous inspection. l The site wide radworker campaign and the i,idor.1 expectation discussions i disassed in the above example will also address this weakness. !
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_ . . _ .- . __ . .. - DEC-C3-98 18:09 Fres:AND CSB 1 5818584685 T-204 P.@l/97 Job-950 > - - . , . FAX dy/o - . , , , , Nurnber of gesincluding cover sheet f kNI lMO (h1/98/lhVf ro: FROM: \\ ' Arkansas Nucleafone ! Entetgy Operations 1 1448 S.R. 333 Russellville, AR 72801 ol/fh'fll l Phone Phone (501) 858 f// Fax Phone llYhhh~//// Fax Phone (501) 858 4685 l
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