IR 05000313/2008007

IR 05000313-08-007, 05000368-08-007, on 07/07/2008, Arkansas Nuclear One, Units 1 and 2, Radiation Safety Team Inspection Report

ML082330515
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/20/2008
From:	Greg Werner Division of Reactor Safety IV
To:	Mitchell T Entergy Operations
References
IR-08-007
Download: ML082330515 (17)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ust 20, 2008

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000313/2008007 AND 05000368/2008007

Dear Mr. Mitchell:

On July 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One Station. The enclosed report documents the inspection findings, which were discussed at the conclusion of the on site inspection on July 11, 2008, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:

• Radiation monitoring instrumentation;

• Radioactive gaseous and liquid effluent treatment and monitoring systems;

• Radioactive material processing and transportation;

• Radiological environmental monitoring program; and

• Radioactive material control program.

This report documents one licensee-identified finding involving a violation of NRC requirements; however, this finding was of very low safety significance (Green). Because this finding was entered into your corrective action program, the NRC is treating this finding as a noncited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violation or the significance of the noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 East Lamar Boulevard, Suite 400, Arlington, Texas 76011-4125; the Director, Office of Enforcement,

Entergy Operations, Inc. -2-U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Arkansas Nuclear One facility.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Dockets: 50-313; 50-368 Licenses: DPR-51; NPF-6 Distribution:

Senior Vice President Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President

& Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Vice President, Oversight Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Manager, Licensing Entergy Operations, Inc.

Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Associate General Counsel Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995

Entergy Operations, Inc. -3-Senior Manager, Nuclear Safety & Licensing Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Section Chief, Division of Health Radiation Control Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Section Chief, Division of Health Emergency Management Section Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Pope County Judge Pope County Courthouse 100 West Main Street Russellville, AR 72801

Entergy Operations, Inc. -4-Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov )

DRP Director (Dwight.Chamberlain@nrc.gov )

DRP Deputy Director (Anton.Vegel@nrc.gov )

DRS Director (Roy.Caniano@nrc.gov )

DRS Deputy Director (Troy.Pruett@nrc.gov )

Senior Resident Inspector (Alfred.Sanchez@nrc.gov)

Resident Inspector (Jeffrey.Josie@nrc.gov )

Branch Chief, DRP/E (Wayne.Walker@nrc.gov )

Senior Project Engineer, DRP/E (George.Replogle@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov )

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov )

RITS Coordinator (Marisa.Herrera@nrc.gov )

DRS STA (Dale.Powers@nrc.gov )

Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov )

ROPreports ANO Site Secretary (Vicki.High@nrc.gov )

SUNSI Review Completed: __ds__ ADAMS: x Yes No Initials: __ds__

x Publicly Available Non-Publicly Available Sensitive x Non-Sensitive HP:PSB2 SHP:PSB2 SHP:PSB2 HP:PSB2 C:PSB2 C:PBE C:PSB2 DStearns/lmb LRicketson LCarson CGraves GWerner WWalker GWerner

/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

7/28/08 7/28/08 7/24/08 7/28/08 8/18/08 8/18/08 8/19/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-313, 50-368 License: DPR-51, NPF-6 Report: 05000313/2008007; 05000368/2008007 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64W and Hwy. 333 South Russellville, Arkansas Dates: July 7 - 11, 2008 Inspectors: D. Stearns, Senior Health Physicist - Team Leader L. Carson II, Senior Health Physicist L. Ricketson, PE, Senior Health Physicist C. Graves, Health Physicist Accompanied By: J. Razo, Health Physicist C. Conley, Engineering Associate Approved By: Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000313/2008007; 05000368/2008007; 07/07/2008 - 07/11/2008; Arkansas Nuclear One,

Units 1 and 2; Radiation Safety Team Inspection Report.

The report covered a 1-week period of inspection on site by a team of four region-based health physics inspectors. Based upon the results of the inspection, the team did not identify any NRC-identified, or self-revealing violations. However, one licensee-identified violation of very low safety significance (Green) was reviewed by the team. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,

Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified Findings and Self-Revealing Findings

None.

Licensee-Identified Violations

A violation of very low safety significance (Green) was identified by the licensee and was reviewed by the team. Corrective actions taken or planned have been entered into the licensees corrective action program. The violation is listed in Section 4OA7 of this report.

REPORT DETAILS

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance.

The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment;

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage;

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area;

• Licensee event reports, audits, and self-assessments;

• Corrective action program reports since the last inspection;

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies;

• Calibration expiration and source response check currency on radiation detection instruments staged for use;

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training; and

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units.

The inspection team completed nine of the required nine samples.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to:

(1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure;

(2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures;

(3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and

(4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the technical specifications as criteria for determining compliance.

The team conducted in-office inspection and reviewed:

• Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report;

• The implementation of the radiological effluent controls program requirements as described in radiological effluent technical specifications;

• Changes to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Safety Analysis Report;

• Changes to the Offsite Dose Calculation Manual made by the licensee since the last inspection;

• Effluent monitoring instrumentation documentation to ensure adequate methods and monitoring of effluents;

• The program for identifying, assessing, and controlling contaminated spills and leaks;

• The annual effluent release reports and the correlation to the environmental monitoring results; and

• The results from quality assurance audits.

The team conducted an onsite inspection which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review:

• The gaseous and liquid discharge system configuration;

• Selected point of discharge effluent radiation monitoring systems and flow measurement devices;

• The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits;

• Effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors including the projected doses to members of the public;

• Surveillance test results on non-safety related ventilation and gaseous discharge systems (HEPA and charcoal filtration) including the methodology to determine the stack and vent flow rates;

• The identification of non-radioactive systems that have become contaminated;

• Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration;

• The methods used to determine the isotopes in the plant source term, meteorological dispersion and deposition factors, and hydrogeologic characteristics used in the Offsite Dose Calculation Manual and effluent dose calculations including a selection of monthly, quarterly, and annual dose calculations;

• The land-use census;

• The implementation of the voluntary Nuclear Energy Institute/Industry Ground Water Protection Initiative;

• Records of abnormal gaseous or liquid discharges including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report;

• Evaluations of discharges from onsite surface water bodies;

• Routine groundwater monitoring results;

• Self-assessments, audits, and licensee event reports;

• The results of the inter-laboratory comparison program;

• Effluent sampling records; and

• The calibration of post-accident effluent monitoring instrumentation and expected accident source.

The team reviewed the licensees program of problem identification and resolution, including:

• Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long-term corrective actions;

• Problem identification and resolution follow-up activities; and

• Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities.

The inspection team completed three of the required three samples.

b. Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensee=s radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensee=s audit program;

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges;

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides;

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting;

• Shipping records for non-excepted package shipments; and

• Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection.

The inspection team completed six of the required six samples.

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03)

a. Inspection Scope

This area was inspected to ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Annual environmental monitoring reports and licensee event reports;

• Selected air sampling and thermoluminescence dosimeter monitoring stations;

• Collection and preparation of environmental samples;

• Operability, calibration, and maintenance of meteorological instruments;

• Each event documented in the Annual Environmental Monitoring Report, which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement;

• Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection;

• Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits;

• Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas;

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records; and

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection.

The inspection team completed ten of the required ten samples.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

Annual Sample Review

a. Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation monitoring instrumentation (Section 2OS3);

• Radioactive gaseous and liquid effluent treatment and monitoring systems (Section 2PS1);

• Radioactive material processing and transportation (Section 2PS2); and

• Radiological environmental monitoring program and radioactive material control program (Section 2PS3).

b. Findings

The inspection team identified two concerns related to problem identification and resolution.

• During the teams review of the functional tests conducted for the containment high range radiation monitors, errors were noted in the calculation of decay corrected values for the calibration source strength. While the issue was evaluated as not more than minor, the inspectors raised concerns about inadequate self-checking of procedures and work packages by the technicians, inadequate supervisory review of procedure changes which contained the wrong

source half-life value, and inadequate supervisory review of completed work packages which contained the wrong source strength values.

• The inspectors conducted a random review of SCBA qualifications for control room personnel. During questioning, 4 of 11 individuals did not know the size of SCBA mask they were qualified to wear, and at least one individual did not know the staging location for small and large size masks. A similar issue was identified during an NRC inspection conducted in June 2006; however, the corrective actions were not adequate to ensure that operators knew their correct mask size and storage location.

4OA6 Meetings

Exit Meeting Summary

On July 11, 2008, the team presented the onsite inspection results to Mr. T. Mitchell, Vice President Operations, and other members of licensee management, who acknowledged the inspection findings. The team confirmed that no proprietary information had been provided.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.

• Unit 1, Technical Specification 5.4.1 and Unit 2, Technical Specification 6.4.1 require written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, February 1978.

Section 7 of Appendix A includes procedures for the control of radioactivity.

Procedure EN-RP-121, Radioactive Material Control, Revision 3, Section 5.7[1]

states, No item shall be given an unconditional release if any detectable licensed by-product material is known or suspected to be on or in the subject item. Contrary to this requirement, on December 13, 2006, the licensee discovered a contaminated nylon lifting sling outside of a remote radioactive material storage area. When measured by direct frisk, the contamination level was found to be approximately 8000 disintegrations per minute. The finding was determined to be of very low safety significance because it was not associated with ALARA planning or work controls, there was no overexposure or a substantial potential for an overexposure, and the ability to assess dose was not compromised. This issue was placed into the corrective action program as Condition Report C-2006-02056.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Bailey, Technician, Instruments and Controls

D. Callaway, Specialist, Chemistry

L. Collins, Technician, Chemistry

R. Dodds, Manager, Maintenance

G. Doran, Supervisor, Radiation Protection

M. Frala, Supervisor, Chemistry

D. Hicks, Supervisor, Radwaste

T. Madeley, Superintendent, Chemistry

D. Marvel, Supervisor, Radiation Protection

D. Moore, Manager, Radiation Protection

R. Sebring, Supervisor, Radiation Protection

NRC Personnel

A. Sanchez, Senior Resident Inspector

J. Josey, Resident Inspector