IR 05000458/2007010

IR 05000458-07-010; 07/09/2007 - 07/13/07; River Bend Station; Access Control to Radiologically Significant Areas; Radiation Safety Team

ML072340080
Person / Time
Site:	River Bend
Issue date:	08/21/2007
From:	Shannon M Plant Support Branch Region IV
To:	Venable J Entergy Operations
References
IR-07-010
Download: ML072340080 (21)

Text

ust 21, 2007

SUBJECT:

RIVER BEND STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000458/2007010

Dear Mr. Venable:

On July 13, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection 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 inspection report documents one NRC-identified finding of very low safety significance (Green). However, because the finding was of very low safety significance and it was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the noncited violation in this report, 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 DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the River Bend Station facility.

Entergy Operations, Inc. -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) 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/

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-458 Licenses: NPF-47

Enclosure:

NRC Inspection Report 05000458/2007010 w/attachment: Supplemental Information

REGION IV==

Docket: 50-458 License: NPF-47 Report: 05000458/2007010 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: July 9 - 13, 2007 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Louis C. Carson II, Senior Health Physicist, Plant Support Bernadette Baca, Health Physicist, Plant Support Branch Gilbert L. Guerra, C.H.P., Health Physicist, Plant Support Branch Donald L. Stearns, Health Physicist, Plant Support Branch Accompanied By: David C. Graves, Health Physicist, Plant Support Branch Approved By: Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000458/2007010; 07/09/2007 - 07/13/07; River Bend Station; Access Control To

Radiologically Significant Areas; Radiation Safety Team The report covered a 5-day period of inspection on site by a team of five region-based inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 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 3, dated July 2000.

Cornerstone: Occupational Radiation Safety

Green.

The team identified a noncited violation of 10 CFR 20.1902(a) because the licensee failed to post radiation areas in the radwaste building with a conspicuous sign or signs bearing the radiation symbol and the words Caution,

Radiation Area. The licensee posted radiation area signs only at the entrances to the different elevations of the building, instead of at the discrete radiation areas, even though most of the radwaste building was not a radiation area.

Dose rates in unposted radiation areas were as high as 15 millirems per hour.

As corrective action, the licensee posted the discrete areas. Additional corrective action is still being evaluated.

The finding was greater than minor because it was associated with one of the cornerstone attributes (exposure control and monitoring) and the finding affected the Occupational Radiation Safety cornerstone objective, in that, uninformed workers could unknowingly accrue additional radiation dose. Using the Occupational Radiation Safety Significance Determination Process, the team determined that the finding was of very low safety significance because it did not involve: (1) ALARA planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Also, this finding had a cross-cutting aspect in the area of human performance and component of work control because the licensee did not coordinate work activities by incorporating actions to address the need to keep personnel apprised of plant conditions that may affect work activities. (H3.b)(Section 2OS1)

Licensee Identified Violations

None

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS1 Access Control To Radiologically Significant Areas (71121.01)

a. Inspection Scope

This area was inspected to assess the licensees performance in implementing physical and administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls. The team used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the team interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The team performed independent radiation dose rate measurements and reviewed the following item:

• Controls (surveys, posting, and barricades) of radiation areas The team completed 1 of the required 21 samples.

b. Findings

Introduction.

A Green noncited violation of 10 CFR 20.1902(a) was identified for the failure to post radiation areas in the radwaste building with a conspicuous sign or signs bearing the radiation symbol and the words Caution, Radiation Area.

Description.

While making observations in the radwaste building on July 10, 2007, the team identified localized radiation areas in walkways in front of high radiation area and locked high radiation area doors which were not posted as radiation areas. The general area dose rates in front of Door RW106-G2 and RW65-G8 were 6 mrem/hr and 15 mrem/hr, respectively. The only radiation area signs to warn workers prior to entering the radiation areas were at the entrances to the different elevations of the radwaste building. The radwaste building is a large area and according to the licensees surveys, only a small part of the total area had dose rates exceeding 5 millirems per hour.

Analysis.

The team reviewed the applicable guidance in NUREG/CR-5569, Revision 1, Health Physics Positions 036, Posting of Entrances to a Large Room or Building as a Radiation Area, and 066, Guidance for Posting Radiation Areas. Because the area was large and very little of it was a radiation area, the team concluded that posting only the entrances to the area, rather than the discrete areas, was not sufficient to inform radiation workers of radiological hazards in their work areas.

The failure to post a radiation area is a performance deficiency. The finding was greater than minor because it was associated with one of the cornerstone attributes (exposure control and monitoring) and the finding affected the Occupational Radiation Safety cornerstone objective, in that, uninformed workers could unknowingly accrue additional

radiation dose. Because the finding involved the potential for unplanned, unintended dose resulting from conditions that were contrary to NRC regulations, the finding was evaluated using the Occupational Radiation Safety Significance Determination Process. The team determined that the finding was of very low safety significance because it did not involve:

(1) ALARA planning and controls,

(2) an overexposure,

(3) a substantial potential for overexposure, or

(4) an impaired ability to assess dose. Also, this finding had a cross-cutting aspect in the area of human performance and component of work control because the licensee did not coordinate work activities by incorporating actions to address the need to keep personnel apprised of plant conditions that may affect work activities.

(H3.b)

Enforcement.

Part 20.1003 of Title 10 of the Code of Federal Regulations defines a radiation area as an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem in an hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

Part 20.1902(a) of Title 10 of the Code of Federal Regulations states that the licensee shall post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words Caution, Radiation Area. However, on July 10, 2007, the team identified radiation areas in the radwaste building that were not conspicuously posted. As corrective action, the licensee posted the discrete areas. Additional corrective action is still being evaluated. Because the failure to conspicuously post radiation areas was determined to be of low safety significance and was entered into the licensees corrective action program as Condition Report CR-RB-2007-03038, this violation is being treated as an noncited consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000458/2007010-01, Failure to Conspicuously Post a Radiation Area.

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

• Self-assessments, audits, and licensee event reports

• 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

• 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 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 ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, 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:

• Radiological effluent release reports since the last inspection, changes to the Offsite Dose Calculation Manual, radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, program for identifying contaminated spills and leakage and the licensee's process for control and assessment, self-assessments, audits, and licensee event reports

• Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluent

• The licensee's understanding of the location and construction of underground pipes and tanks and storage pools that contain radioactive contaminated liquids; the technical bases for onsite monitoring, the licensee's capabilities of detecting spills or leaks and identifying groundwater radiological contamination both on site and beyond the owner-controlled area

• Changes made by the licensee to the Offsite Dose Calculation Manual, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection

• Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control

• Interlaboratory comparison program results

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Abnormal releases The team completed 11 of the required 11 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 licensees 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 licensees 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

• Shipping records for non-excepted package shipments

• Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting The team completed six of the required six samples.

b. Findings

No findings of significance were identified.

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

a. Inspection Scope

This area was inspected to ensure that the REMP 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 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

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection The team completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

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)

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

b. Findings and Observations

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On July 13, 2007, the team presented the inspection results to Mr. J. Venable, Senior Vice President, Operations, and other members of the staff, who acknowledged the findings.

The team confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Albert, Supervisor, Health Physics

R. Anthony, Supervisor, Health Physics

T. Baccus, Senior Health Physicist, Radiation Protection

B. Biggs, Technical Specialist, Licensing

T. Griffiths, Measuring & Test Equipment Supervisor

D. Heath, Supervisor, Health Physics (Radwaste/Shipping)

R. Heath, Supervisor, Chemistry

B. Houston, Manager, Radiation Protection

K. Huffstatler, Technical Specialist, Licensing

J. Hurley, Supervisor, Health Physics

M. Laiche, Senior Health Physicist, Radiation Protection

B. Michura, Master Nuclear Environmental Technician, Chemistry

B. Olinde, Superintendent, Instruments and Calibration

M. Reeves, Studsvik Transportation Representative

D. Sandlin, Engineer, Systems Engineering

W. Spell, Senior Environmental Specialist, Chemistry

S. Zabaski, Senior Health Physics/Chemistry Specialist, Chemistry

M. Vierra, Technical Specialist, Health Physics

NRC

M. Miller, Resident Inspector

D. Bollock, Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Opened and Closed During this Inspection

05000458/2007010-01 NCV Failure to Failure to Conspicuously Post Radiation Areas (Section 2OS1)

Attachment