ML20197J039
| ML20197J039 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/18/1997 |
| From: | Mims D ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 0CAN129708, 50-313-97-19, 50-368-97-19, CAN129708, NUDOCS 9801020061 | |
| Download: ML20197J039 (5) | |
Text
_
f m
4Bntergy. '
M E*'~' '~'
. Russohse, AR 72801 Tel501858-5000 10CFR2.201 December 18,1997 3
OCAN129708 -
U.~ S. Nuclear Regulatory Commission Document Control Desk Mail Station OPI-17 Washington, DC 20555
- Subjecti
' Arkansas Nuclear One - Units 1 and 2
. Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response To Inspection Report 50-313/97-19;50-368/97-19 Gentlemen:
Pursuant to the provisions of 10CFR2.201, attached is the response to the notice of violation identified during the inspection activities associated with the radiation protection program.
Should you have any questions or comments, please call me at 501-858-4601.
Very truly yours, 4 L i e c. m Dwight C. Mims Director, Nuclear Sefety DCM/ajs
'l
~ Attachments 1mb 9001020061 971219
~
PDR ADOCK 05000313 O
PDR; 11'ilIlli.lllllllll' wecosi e
v
i
. U. S. h10
,, December 18,1997 PAGE2
' cc:
'Mr. Ellis W. Merschoff Regional Admini.tratcr J
- U. S. Nuclear Regulatory Commission j
Region IV -
l 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission
- NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 4
b
' Attachment to"
=
0CAN129708 -
3 Page1of3.
During an NRC inspection conducted on November 3-6, 1997, a violation' of NRC requirements was identified. In accordance with the " General Statements of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
Unit 1 Technial Specification 6.10 and Unit 2 Technical Specific.ation 6.11 state, in past, " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure." Procedure 11012.020, Section 6.2.4.C states, in part, " Store sources only in areas designated' L
- by the source custodian responsible for the sources and approved by the Manager, j
s Radiation Protection / Chemistry." Proce ure 1012.020, Section 6.2.5.D, states, in d
part, "Each time a source utilizing an ANO source number is removed from its storage area, log the required information on the 1012.020", ' Source Temporaiy Signout' located at the storage location."
Contrary to the above, on November 5,1997, the licensee failed to store a 5 millicurie Ni-63 source in an area designated by the source custodian. responsible -
for the source and approved by the Manager, Radiation Protection / Chemistry and failed to ensure that the source location was logged on the " Source Temporary Signout."
Tiiis is a Severity Level IV violation (Supplement IV)(50-313;368/9719-01) e ResponE_tp Notice Of Violation 313/9719-01: 368/9719-01 (1) Reason for the violation:
Source number 1575 at Arkansas Nuclear One (ANO) is a 5 millicurie nickel (Ni-63) 1 source installed in an analyzer used by the chemistiy department to detect air-in-leakage into the main condense s.
This analyzer is installed in plant systems as required for in-leakage detection and then removed and stored. Historically, it has e
been installed for long periods of time when the plant experienced main condenser air
-in-leakage problenis; On November 5,'1997, the analyzer containing source 1575 was found stored in a locker that was not designated for stwage of radioactive sources. The root causes cf
- this, error were the lack of a clearly visible " Radioactive Material" label on the outer
- surface of the analyzer and a lack of procedure instmetions for "in-use" sources.
k i
.a
l Attachment ts
,, OCAN129708 Page 2 0f 3 There is an etched alumin'im plate on the outer surface of the analyzer cabinet that indicates the equipment contains a radioactive source, but it is not readily visible. The ANO radioactive material source label was placed directly on the source enclosure located internally to the analyzer cabinet.
Originally the analyzer was mounted on a cart and posted with barrier rope and a posting sign as " Radioactive Material, TLD Required " Because the Ni-63 source is a low energy beta emitter with no detectable external radiation and the analyzer was innalled in the plant syste.a for an extended period of time, the controls were subsequently relaxed and the posting was removed from the cart. This resulted in no readily visible identification on the exterior of the instrument that identified it as having an internally installed radioactive source.
In 1994, this analyzer was usad extensively. Due to the frequency of use and long periods of time the unit was installed in the system, the radiation protection (RP) source custodian determined that the instmment, net the criteria for a "in-use" source. Procedure 1012.020, Radioacthe Material Control, defines "In-Use Source Lccation" as "an area where sources are used permanently or semi-permanently either in plaat systems or components." The procedure, however, does not provide any instmetions for storage of"in-use" sources that are disconnected from plant systems.
The "in-use" source designation would allow the source to ( : used in much the same way as the process and radiation monitors installed on various plant systems. Tius designation should not apply to equipment that is temporarily connected to syster...
and then removed for storage.
Due to the lack of procedure guidance and the verbal information from the previous RP source custodian, the c m.istry source custodian and equipment users incorrectly 5
interpreted the requirements for use of this equipment as an "in-use" source. Because the analyzer needed to be readil;. available, it was stored in a locker close to where it would be installed in the system. The users did not understand that, when removed from the sytem, source 1575 was under the same controls as other sources. Sourc,.s not ir.-use cannot be left unattended and must be stored in an approved source storage location.
(2) Corrective steps that have been taken and the resultiachieved:
The analyzer containing source 1575 was removed from the un-approved locker and retumed to the assigned storage area in the chemistry count room.
Ar. inventory was performed on other sources used by the chemistry group and no di crepancies were found.
Attachment to
[
,,0CAN129708 Page 3 of 3 7,
Source storage and "in-use" source requirements were reviewed with the chemistry source custodian.
A " Radioactive Material" label was added to the outside surface of the analyzer containing source 1575.
Procedure 1012.020, was clarified to state that "in-use" soucces did not include sources used in more than one location and to provide instructions for "in-use" sources removed from the system.
(3) Corrective steps that will be taken to avoid further violations:
The condition and lessons learned from this event will be reviewed with ANO source.
users by February 20,1998.
2 (4) Date when full compliance will be achieved:
Full compliance was achieved on Noven:ber 5,1997, when source 1575 was returned to the designated storage foc.aion in the chemistry count room.
J
_