IR 05000313/1997019

Insp Repts 50-313/97-19 & 50-368/97-19 on 971103-06. Violations Noted.Major Areas Inspected:Exposure Controls, Radioactive Matl & Contamination,Surveying,Monitoring & Quality Assurance in Radiation Protection Activities

ML20202C380
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/28/1997
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20202C334	List: IR 05000313/1997019 ML20202C329 ML20202C350
References
50-313-97-19, 50-368-97-19, NUDOCS 9712030321
Download: ML20202C380 (13)

Text

- -. .. .. ..

.

.

_

.

<

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50 313 50-368 License hos.: DPR 51; NPF-6 Report Fo.: 50-313/97 19;50-368/97 19 Lice.isee: Entergy Operations, In Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64W and Hwy.333 South Russellvitie, Arkansas Dates: November 3 6,1997 Inspectors: L. T. Ricketson, P.E., Senior Radiation Specialist Plant Support Branch G. L. Guerra, Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Bonch Division of Reactor Safety Attachment; Supplemental information 9712030321 971129 PDR ADOCK 05000313 G PDR 2

. .

. _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ ..

_

-

.

EXECUTIVE SUMMAf0f Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report 50 313/97 19;50 368/97 19 The announced, routine inspection reviewed the radiation protection program. Areas reviewed included: exposure controls, controls of radioactive material and contamination, surveying and monitoring, the program to maintain occupational exposure as low as is reasonably achievable (ALARA), training and qualifications, and quality assurance in radiation protection activitie PJant Suonort

• Exposure controls were implemented appropriately. High radiation areas were controlled properly. Radiological area posting was correct. Dosimetry was properly used. Dosimetry records were maintained as required. Good respiratory protection and whole body counting programs were implemented (Section R1.1).

• There were vulnerabilities in the licensee's program for conditionally releasing items from the radiological controlled area that could result in the loss of control of radioactive material (Section R1.2).

• A violation was identified because the licensee f ailed to secure radioactive material from unauthorized removal or access and f ailed to store a radioactive source in accordance with procedural requirements (Section R1.2).

• The ALARA program produced good results. The 3-year average exposure per unit was below the national average for pressurized water reactors. For 19941997, the site 3-year average person tem totals declined significantly. ALARA improvement ideas and lessons learned were captured and utilized well (Section R1.3).

• Good training programs were implemented for radiation protection technicians and professionals. The topics ddressed in radiation protec:;on training were appropriate. Professionals were provided sufficient opportunities to maintain a satisf actory level of expertise. The radiation protection organization was adequately qualified (Section RS).

• Licensee oversight of radiation protection activities was good. Corporate assessments and quality assurance surveillances were frequent and diverse enough to provide management with accurate information on the effectiveness of the radiation protection program. The licensee eficctively implemented corrective actions in a timely manner for identified conditions ISection R7).

I

__ - _ - - _ _ _ _ - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - -

-. _ _ _ _ _ _ _ __-

.

,

3- l Report Details IV. Mant S"aaa t i

R1 Radiological Protectioni and Chemistty (RP&C) Controls >

RI .1 External Exoomure Contrgjs i insnection Scone (83750) {

The inspectors interviewed radiation protection personnel and reviewed the following:

!

• Control of high radiation areas

• High radiation area key control

• Radiological posting

• Radiological controlled area access controls

• Dosimetry use by radiation workers

• Dosimetry record keeping

• Skin dose measurements i

• Radiological air sampling techniques

• Respirator issue and use

• Respirator inspection and maintenance ,

'

• Breathing air certification

• Whole body counting , Observations and Findinas (83750)

During tours of the radiological controlled area, the inspectors noted high radiatio's areas

'

were controlled and posted properly. Proper radiological controlled area access controls were implemented. Dosimetry was used appropriately by worker '

Personnel dosimeters were processed by the Waterford Unit 3 facility. The results of the dosimetry analyses were recorded in the licensee's computer data base, and the system assigned doses to the proper individuals. The inspectors determined that the licensee's compuur system effectively maintained the required information for NRC Forms 4 and The inspectors verified that exposures assigned to personnel who wore multiple badges or who received an internal exposures were correctly recorded in the computer data base.

l The inspectors noted that records were available and easily retrievabl .

-Whole body counting was conducted on individuals if they were involved in a j

contamination event in which there was a potential for internal deposition of radioactive i material. Five individuals were assigned doses as results of radioactive materials taken internally. These doses were accurately recorded in the dosimetry record system. Skin .

- doses, resulting from personnel contamination events, were calculated correctly and ,

recorded as required. The inspectors determined that the licensee properly implemented its whole body counting and dose assignment progra <

5 e.. ., ..,..m . .. . .m., _ , ... .,,,.,.,,,,...e,,e

-

._.,_;,,-.m., , ,., _ , -,e , ,,m . , , , ,,, ,,

.

.

-4-Radiological air samphng was performed routinely in certain areas of the plant. The inspectors verified through records review that airborne radioactivity concentration was calculated and recorded correctly. The inspectors reviewed Procedure 1601.301,

• Radiological Surveys," Revision 5, and concluded that it provided good guidanc Respirator issue was also tracked on the computer system. The system performed verifications to ensure individuals met qualification requirements and ensured that respirators matched the sizes worn during fit testing. Through records review and personnel interview, the inspectors determined that the respirator issue program was implemented correctly. Respirators were inspected every 30 days, as required by licensee procedure. Only minor maintenance was performed by the licensee. Used respirators were sent to a central f acility at the Grand Gulf Nuclear f acility for reconditioning, repair, and disinfecting. The licensee maintained two compressors for filling self-contained breathing apparatus bottles. An independent laboratory analyzed the licensee's quality of breathing air quarterly. The inspectors reviewed records of breathing air analyses and noted no problem A Total Effective Dose Equivalent /ALARA dose benefit curve was included in licensee procedures and used to determine it respirator use was appropriate for any specific radiological conditions. No respirators were issued for radiological safety, thus f ar, in 1997. The inspectors concluded that a proper respirator protection progrt was implemente Conclusons Exposure controls were implemented appropriately. High radiation areas were controlled properly. Radiologit al area posting was correct. Dosimetry was properly used. Dosimetry records were maintained as required. Good respiratory protection and whole-body counting programs were implemente '11.2 Control of Radioactive Material and Contamination: Survevina and Monitorina Insoection Scooe (83750)

The inspectors interviewed radiation protection personnel and reviewed the following:

• Portable survey instrument calibration

• Release of radioactive material from the radiological controlled area

• Control ci sealed radioactive sources

• Leak testing of sealed sources Observations and FirulinOS During tours of the radiological controlled area, the inspectors verified that portable radiation detection instruments weie calibrated and performance tested properly. Portable radiation detection instruments were calibrated at a central f acility located that the Grand Gutt Nuclear Station.

._

F

'

(

.

5-During Inspection 50-313/97 15; 50-368/97 15, the inspector noted, during a review of condition reports, examples of radioactive material unintentionally released from the radiological controlled area. A violation was identified, because the requirements for unconditional release were not met. The inspectors identified no additional examples during thio inspection. However, the inspectors identified vulnerabilities in the licensee's program to control radioactive materials and a potential means by which the licensee could loose accountability of some items contaminated with radioactive materia Accord ng to Procedure 1012.020, " Radioactive Material Control," Revision 4, items not meeting the requirements for unconditional release from the radiological controlled area could be released if certain other conditinns were met. These conditions included:

• Packaging and tagging or labeling the item (s)

• Documenting the release on Form 1012.020M

• Securing the signature of individual responsible for the item (s)

The inspectors attempted to verify the locations of selected items listed on conditional release records. One of the first things noted by the inspectors was the lack of a means to uniquely identify allitems released. Without unique identification, there was no way to ensure the licensee maintained accountability on the entrect item. Some items, such as tools, carried an engraved number that was unique to each tool. However, the inspectors noted examples in which the unique numbers were not used even though they were available. Specific examples were observed on release records dated January 28 and August 27,199 The licensee's means of maintaining accountability depended on the memories of the individuals to whom the material was released. Conditional release records listed the individuals removing the items from the radiological controlled area; records did not list the location where the material was to be taken or stored. In many cases, there was only anecdotal evidence of the pathway followed by conditionally released items. If the person

to whom the material was released was unavailable, locating the item (s) was even more I difficult. Such was the case if the material was released to an employee or contractor who had terminated employment, lilegible signatures presented another potential difficulty in tracing released items. However, in most cases, the security badge number of the individual removing items was included with the individual's signature. The inspectors noted that the procedural guidance did not require the security badge number to be include Thu inspectors confirmed that the licensee maintained positive control of some conditionally released items. These included tools, when unique identification numbers were used, and items that were first conditionally released for isotopic analysis by the chemistry department, items in the latter group were linked to the unique numbers of the

! isotopic analyses results.

l l For other items, the results of the inspectors * review were inconclusive, since many items were not uniquely identified. It was the licensee's position that allitems selected for verification were located. The inspectors identified no examples in which the licensee

l I

. - - - . - - --

-

.

,

-6-unquestionably f ailed to maintain accountability of an item released from the radiological controlled are Licensee representatives acknowledged the inspectors' comments regarding the vulnerabilities of the licensee's program for the conditional release of radioactive material and the associated procedural guidance. Licensee representatives stated that they would conduct discussions with other nuclear sites to determine how materials were controlled and eview the guidance in their procedure to determine if changes were warranted, in another area related to the licensee's control of radioactive rnatorial, the inspectors reviewed the list of sealed source storage areas, approved by the radiation protection manager, and attempted to confirm that selected sealed sources were stored appropriatel During a physical inventory, the inspectors determined that Source 1575, a 5 millicurie Ni 63 source assigned to the chemistry counting room, was not stored in the assigned storage area. Additionally, there was no indication of the source's location on the source signout log. After discussions with several chemistry technicians, the inspectors and licensee representatives found the source in an unlocked, metal cabinet outside Unit 2, but within the protected area. The inspectors were unable to determine when the source was first stored in the cabinet. Howev'ar, during the most recent sealed source inventory, performed in July 1997, licensee representatives documented that the t.ource was stored in the chemistry count roo Procedure 1012.020, Section 6.2.4.C states, in part, " Store sourcen only in areas designated by the source custodian for the sources and approved by the Manager, Radiation Protection / Chemistry." Procedure 1012.020, Section 6.2.5.D, states, in part,

"Each time a source utilizing an ANO source number is removed from its storage area, log the required information on the 1012.020H, ' Source Temporary Signout' located at the storage location."

The inspectors identified the f ailure to secure radioactive material from unauthorized removal or access and the f ailure to store the radioactive source in accordance with procedural requirements as a violation of Unit 1 Technical Specification 6.10 and Unit 2 Technical Specification 6.11 (50 313; 368/9719 01).

The licensee initiated Condition Report C-97-0325 to document the problem and track corrective action Conclusions There were vulnerabilities in the licensee's program for conditionally releasing items from the radiological controlled area that could result in the loss of control of radioactive material. A violation was identified, because the licensee f ailed to secure radioactive material from unauthorized removal or access and f ailed to store a radioactive source in accordance with procedural requirements.

l l

!

l

. . _ _ . . _ . .- _

_

!

.

R t .3 Maintainino Occuoational Exoosure ALARA Insoection Scooe (8371Q1 The inspectors interviewed radiation protection personnel and reviewed the following:

• ALARA goals /results

• Implementation of previous lessons learned

• ALARA committee activities

• ALARA suggestions

• ALARA initiatives Observations and Findings ALARA comrnittee meetings were attended well by representatives from all departmi nts, indicating good support for the program. The number of meetings held throughout the year was appropriat Procedure 1012.027, "ALARA Program," Revision 2, implemented an ALARA improvement ideas program. No tracking system was used to monitor the evaluation and implementation of ALARA suggestions. When questioned, at first, radiation protection personnel did not know the number of ALARA suggestions submitted in 1997 nor the number implemente Subsequently, the licensee determined that only one suggestion had been formally submitted for 1997. The licensee stated that all suggestioni forms submitted were evaluated, and a response was given to the originator. Furthermore, the licensee stated that most improvement suggestions were verbally conirnunicated to ALAPA coordinators, and use of the improvement forms was minima Despite the informal means of collecting improvement ideas, the inspectors noted that the licensee maintained a very good data base for ALARA planning purposes, historical radiological information, and lessons learned from previous work activities. The major input to this data base was information collected from supervisor memos and post job briefing Post job briefings, to capture lessons learned and improvement ideas, were held for all major activities, not just those required by the licensee's procedure guidance. The inspectors concluded that this was a proactive initiativ Action items were initiated for items identified to be of benefit in maintaining exposures ALARA. Licensee management's expectation was that the iction items be addressed before the next outage. The inspectors noted that the licensee maintained an action item list generated from Unit 2 Refueling Outage 12 and *t implementation status was tracke The 3 year average site exposure (per unit) for 1993-1997 is shown below. The results of the licensee's ALARA initiatives were reflected in the decline of the Arkansas Nuclear One 3-year exposure averages. Based on the licensee's prior performance, ALARA goals were challengin ___ ___ ____-__-__-___ _ ___- -_ ______ ______ _______________ _ __ _

__-- - _ _ . - _ . . _ . , ,-

E

,

.

-8-1993 1994 1995 1996 1997*

Licensee's 3 year 248 217 136 127 119 average per unit National PWR 194 133 170 131 average

• 1997 exposure projection Concluslom The ALARA program produced good results. The 3 year average exposure per unit was below the natkenat werage for pressurized water teactors. For 1994 1997, the site 3-year average person rem totals declined significantly. ALARA improvement ideas and lessons learned were captured and utilized wel R5 Staff Training and Qualification Insoection ScopsEL,"Tt01 The inspectors intervic ved radt tion protection personnel and reviewed the following:

• Radiation protection ;echnician continuing training curriculum

• Radiation protection supervisor and professional training

• Membership in professional organizations Findinos and Qbservatiom Continuing training was presented in 4 to 6 cycles per year with each cycle lasting 5 weeks. Continuing training was required for all radiation protection technicians, specialists, and supervisors. Baselining exams were used to assess fundamental knowiedge and to determine needed training topics for the radiation protection staff. Radiation protection personnel worked with training department personnelin determining the scope of training provided during the continuing training cycles. Each cycle provided 18-24 hours of training to the radiation protection staff. The inspectors reviewed the topics presented in continuing training in 1996 and 1997 and concluded that they were appropriat Licensee management was active in emphasizing plant systems training, lessons learned, and fundamental knowledg The supervisors and professionals within the radiation protection organization were given frequent opportunities to attend off-site training, professional meetings, or peer visits. The inspectors concluded this indicated good management support by allowing continuing training in the professionals' field of expertis During a review of qualifications and professional development, the inspectors noted that 14 of the 67 members of the radiation protection organization successfully completed the requirements for registration by the National Registry oi Padiation Protection Technologist ._

E

.

.

. Of these, two were assigned to the radiation protection operations group. The inspectors concluded that this was a relatively low percentage of the staff. The inspectors also determined that there were no certified health physicists on the radiation protection staf There were no regulatory requirements associated with these observation Conclusions Good continuing training prograr1s were implemented for radiation protection technicians and professionals. The topics addressed in radiation protection continuing training were appropriate. Professionals were provided sufficient opportunities to maintain a satisfactory level of expertise. The radiation protection organization was adequately qualifie R7 Quality Assurance in RP&C Activities Insocetion Scone 183750)

The inspectors reviewed the following:

• Quality assurance surveillances

• Self assessments

• Condition reports Observations and Findinos The licensee utilized audits, surveillances, and assessments to evaluate the effectiveness of the radiation protection program. The inspectors noted that frequent surveillances of radiation protection activities nre performed by quality assurance personnel. No audits of the radiation protection program had been performed since the last NRC inspection in this area. A corporate assessment of radioactive material control was performed. The assessment used technical specialists from other nuclear power generating f acilities. The quality of the assessment was good. Implementation of suggested improvement items was tracked by the radiation protection departmen The insp?ctors noted that the licensee's identification threshold for generating condition reports was proper and that the licensee was effective in evaluating the conditions and taking proper corrective action as warranted. Corrective actions were initiated in a timely manner. No negative trends were identified by the inspectors during this review, Conclusions Licensee oversight of radiation protection activities was good. Corporate assessments and quality assurance survoi! lances were frequent and diverse enough to provide management with accurate information on the effectiveness of the radiation protection program. The licensee effectively implemented corrective actions in a timely manner for identified condition .

.

-10-R8 Miscellaneous RP&C lasues (Ootal Violation 50 313: 50-36H/9715-01: Failure to control unauthorized access to a locked hioh radiation area and f ailure to deterrnine the radiological conditions.jD a work area The inspectors determined that the licensee had not implemented all corrective actions described in the licensee's response dated August 11,1997. Corrective actions were not expected to be complete until January 15,199 .2 (Closedl Violation 50-313:50-368/9715-02: Failure to maintani control of radioactive matcIlal.outside the radiolooical controlled ar The inspectors verified the con ective actions described in the licensee's response letter, dated August 11,1997, were 'mplemented. No additional problems were identified dealing specifically with the unconditisnal release of radioactive materia YlddlagemenLMeniing X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee menagement at an exit meeting on November 6,1997. The licensee acknowledged the findings preeente N: proprietary information was identifie _ - _ _ . -- _ -- _- _ _ _ _ _ - _ _ - _ _ _____

_

,

ATTACHMENT PARTIAL LIST OF PERSONS CONTACTEC Licensee G. Ashley, Licensing Supervisor

,

R. Bement, Radiation Protection / Chemistry Manager R. Edington, General Manager D. Fowler, Quality Assurance Supervisor E. Frix, Radiation Protection Operations Shift Supervisor D. Mims, Licensing Director T. Roiniak, Dosimetry Supervisor A. South, Licensing Specialist J. Smith, Radiation Protection Superintendent R. Schwartz, Health Physics Specialist EfiC J. Melfi, Acting Senior Resdent inspector ,

S. Burton, Resident inspectoi INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED ,

,

Onened 50 313:368/9719-01 VIO Failure to store a radioactive source in accordance with procedural requirements; f ailure to secure radioactive material from unauthorized removal or access Closed 50 313;368/9715 02 VIO Failure to maintain control of radioactive material outside the radiological controlled area Discussed 50-313;368/9715 01 . VIO Cailure to control unauthorized ac:ess to a locked high radiation area and failure to determine the radiological conditions in a work area

, . . . . , . .. . . , . . 4 - .. - . . _ - . _ . . - , - , . . - _ . . .

_ . , , - , , . .

_ . . ~ _ _ - - . . _ _ - - . _ . _ -

l

.

l

.

2- )

LIST.OEACRONYMS USED ALARA As low as is reasonably achievable ERIMS Entergy RadiologicalInformation Management System TLD Thermoluminescent dosimeter LIST.OF DOCUMENTS REVIEWED i

P_tacaduras 1012.020, Radioactive Material Control, Revision 4 1012.026, Respiratory Protection, Revision 2 1012.027, ALARA Program, Revision 2 1601.201, Issue and Control of TLDs, Revision 3 1601.205, Personnel Dose Assignrnent, Revision 4 1601.603, Breathing Air, Revision 1 Assessments and Surveillances 6 Radioactive Material Control Assessment, July 21 24, 1997 Quality Assurance Surveillance Reports:

Sh-025 97, "Radworker Practices / Contamination Control," June 16,1997 SR-026 97, " Radiological Postings," June 16,1997

SR 036-97, "HP Job Coverage During 2R12," August 8,1997

.

SR 037 97, "Whole-Body Counting," August 11,1997-

,

SR-039 97, " Documentation Completeness of Routine RP/RW Tasks," August 22,1997 SR-046 97, " Radiological Postings outside Controlled Access," September 10,1997 g

, . . - . - _ , . . . .

- - . . - - - - - - _ - - _ -

?

d

.

Other Documents Radiation protection organization chart dated 10/20/97 List of condition reports and radiologicalinformation reports assigned to the Radiation Protection organization for disposition since the beginning of the assessment period (July 7, 1996).

List of topics covered in RP technician continuing training during 1996 and 1997 1997 ALARA Committee meeting minutes I

!

Unit 2 Refuel 12 ALARA Success Report Octobor 1997 Radiation Protection Monthly Report-i

.

P i-

.

!

!

-r

!:

,

!

-. ;

,

,

, _ ._. .-.-. .._,._ -... . , . - . . - . . - - . - , . . . - - .. ,..~ -., _ ~ ,m, . . ~ - -. . --.- - - _ . - _ ..