IR 05000331/1998007
| ML20247K339 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 05/12/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247K320 | List: |
| References | |
| 50-331-98-07, 50-331-98-7, NUDOCS 9805220072 | |
| Download: ML20247K339 (21) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50-331 License No: DPR-49 l Report No: 50-331/98007(DRS)
Licensee: IES Utilities In Facility: Duane Arnold Energy Center Location: IES Utilities In First Street SE P.O. Box 351 Cedar Rapids, IA 52406-0351 l
Dates: April 13 to May 4,1998 Inspectors: Steven K. Orth Senior Radiation Specialist l Kara N. Selburg Radiation Specialist i
Approved by: Gary L. Shear, Chief, Plant Support 2 Division of Reactor Safety l 9805220072 980512 L
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EXECUTIVE SUMMARY Duane Arnold Energy Center, Unit 1
. NRC Inspection Report 50-331/98007 This announced inspection included an evaluation of the effectiveness of aspects of the
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radiation protection (RP) and chemistry programs. Specifically, the inspectors reviewed the '
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radiological planning and controls for work conducted during the ongoing refueling outage, including ALARA reviews, outage dose trending, radiation work permits, and radiation worker practices. In addition, the inspectors reviewed actions conceming previous inspection issue During the inspection, six violations of NRC requirements were identifie Plant Sunoort
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One violation was identified concerning the inadequate evaluation of the radiological effects incident to the low pressure core injection system full flow testing on April 4, 1998. Specifically, the licensee failed to adequately evaluate the effect of operational l changes on radiological conditions within the facility, which resulted in areas that were l not properly posted and controlled as high radiation areas. (Section R1.1)
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During plant walk-downs, the inspectors found radiological hazards in the facility to be acceptably controlled and posted. Personnel were knowledgeable of radiological conditions and requirements. However, the licensee identified an RP technician who was inattentive to duty, in addition, the inspectors observed several radiological housekeeping problems in the reactor drywell and the radwaste building which l challenged effective contamination control. (Section R1.2)
i l . The inspectors concluded that the staff maintained effective oversight of accumulated i outage dose. ' Although the RP staff did not utilize formal methods, the staff performed comparisons of radiation work permit totals to outage goals and provided graphical representations of outage performance for licensee management. (Section R1.3)
. Two violations were identified conceming the failure to properly adhere to radiation work permit requirernents and the failure to properly post the torus as a high radiation are In addition, the inspectors identified weaknesses in the radiological controls and planning of the torus diving evolutions. Although no unexpected personnel doses occurred during the diving activities, the RP staff did not fully consider or evaluate NRC generic communications conceming controls and barriers to prevent divers from l
receiving unplanned exposures from underwater radiation sources. (Section R1.4)
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. The planning for the installation and removal of shielding properly addressed radiological controls. The ALARA Review incorporated lessons learned from previous work performed at the facility and addressed anticipated radiological conditions.
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. Two examples of a violation were identified concerning the failure of two workers to properly adhere to RP controls for entry into a high radiation area. Although the
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'a licensee's review of the incident was thorough, the violation was similar to a previous NRC Notice of Violation for not adhering to RP work instructions. The inspectors identified that problems in comrr,unications, worker performance, and RP technician oversight contributed to the incident. (Section R4.1)
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Four examples of a violation of station procedures were identified concerning incidents in which personnel entered radiation areas and high radiation areas but did not have the
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proper dosimetry. The licensee identified and documented six similar incidents in which individuals had entered radiological areas with either inactivated electronic dosimeters or without electronic dosimeters. Although the licensee performed adequate assessments of worker doses, the incidents indicated a lack of personnel attention to RP requirements. In addition, corrective actions for a similar, previous non-cited violation were not adequate to prevent these incidents. (Section R4.2) ,
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One violation was identified concerning the training of chemistry technicians on the post l accident sampling system. The inspectors identified that three technicians had not l performed surveillance at the 2 year frequency required by procedure to maintain qualification on the post accident sampling system. This failure indicated a lack of thoroughness in the licensee's actions to resolve post accident sampling system training problems previously identified by the NRC. (Section 8.1) I
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The licensee's actions to resolve issues regarding the capability of the post accident sampling system to obtain representative samples of containment atmosphere for iodine analysis were not timely. Although the issue had been identified in early 1997, the i licensee had not addressed the problem until the time of this inspection. (Section R8.3) !
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Reoort Details IV. Plant Suonort l R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Inadeouate Radiological Evaluation of Operational Activities Insoection Scoce (IP 83750)
The inspectors reviewed the effects of the April 4,1998, low pressure core injection (LPCI) full flow test on radiological conditions in the torus area and the lower elevations of the reactor building. The inspectors reviewed radiological suntey records and discussed the incident with applicable members of the radiation protection (RP) staf Observations and Findinas
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On April 4,1998, the licensee conducted a full flow test associated with the LPCI system. During the test, the licensee directed the flow of three residual heat (RHR)
pumps into a single injection line for about 10 to 15 minutes, which was a unique evolution at the site. Although the licensee routinely performed radiological surveys after initiation of RHR pumps, the operations and RP staffs incorrectly assumed that this test would not affect radiological conditions in the plant. However, following the testing, radiation levels in the torus area and the southeast and northwest corner rooms of the reactor building significantly increased (e.g., four to five times the levels prior to the test), resulting in high radiation areas (HRAs) that were not properly poste The inspectors discussed the incident with a member of the RP staff who was at the f
radiologically controlled area (RCA) access control desk at the time of the tes !
Although the testing had been communicated to the plant staff via plant meetings and the published schedule, the RP technician indicated that the RP staff had not been informed prior to the change in the operations of the RHR pumps. Instead, the individual indicated that the RP staff learned of increased radiation levels in the plant from workers who were in the affected areas and, subsequently, questioned the operations staff on operational changes which may have led to the increased level For example, an engineer notified the RP staff that he had received an electronic dosimeter (ED) dose rate alarm while performing vibrational measurements near one of the RHR pumps. In addition, an operator notified the RP staff of abnormally high radiation levels in another area of the reactor building. Subsequently, the RP staff restricted access to the known affected areas and dispatched RP technicians to perform surveys in the areas. The RP technicians identified general area radiation levels between 100 and 200 millirem per hour (millirem /hr)in the following areas: (1) bays 5 through 15 of the torus room, (2) 731' and 736' elevations of the reactor building southeast corner room, and (3) 716' elevation of the reactor building southeast corner room. Consequently, the RP staff established HRA boundaries and postings in the
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above areas, which were previously posted as radiation areas. Although personnel had received ED dose rate blarms, the inspectors verified that no unplanned exposures resulted from the inciden CFR 20.1501(a) requires, in part, that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 I
and that are reasonable under the circumstances to evaluate the extent of radiation levels and the potential radiological hazards that could be present. Survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. The failure of the licensee to adequately evaluate the potential radiological hazards that were incident to the April 4,1998, LPCI full flow testing to ensure that radiological hazards were posted in accordance with the requirements of 10 CFR 20.1902(b)is a violation of 10 CFR 20.1501(a) (VIO 50-331/98007-01).
After recognizing the unexpected increase in radiation levels, the licensee implemented conservative actions to evaluate the incident and determine actions to reduce the radiation levels in the areas. Following the test, the licensee maintained a single RHR pump in operation, which did not alter conditions. The chemistry staff performed isotopic analyses of the reactor coolant which indicated a significant increase in the quantity of insoluble radioactive corrosion products. On April 6,1998, the licensee placed RHR pumps A and C into operation, which discharged through the common cross-tie into the B recirculation loop, to flush the radioactive corrosion products from the RHR cross-tie and discharge lines. Following this evolution, the RP staff performed surveys and identified that radiological conditions returned to the pre-April 4,1998, levels. Although the licensee partially attributed the unexpected dose rates to the increase in injection flow (i.e., three RHR pumps) through the single injection point, the licensee had not completed its investigation into the inciden Collclusions One violation was identified concerning the inadequate evaluation of the radiological effects incident to the LPCI system testing on April 4,1998. Specifically, the licensee failed to adequately evaluate the effect of operational changes on radiological conditions within the facility, which resulted in areas that were not properly posted and controlled as HRA R1.2 Plant Radiological Conditions Insoection Scooe (IP 83750)
The inspectors reviewed the radiological conditions of the plant and assessed the posting of radiological hazards, the control of contamination boundaries, and the control of HRAs. The inspectors also observed radiation practices of personnel performing work in the facilit _ _ - _ _ _ _
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l b. Observations and Findinos l
During inspections of the RCA, the inspectors observed that contamination areas, radiation areas, and HRAs were adequately posted and controlled. However, the inspectors observed previous posting problems in the torus and reactor building (Sections R1.1 and R4.1). In addition, the inspectors observed radiological housekeeping problems in the drywell and in the radwaste building. In the reactor '
drywell, the inspectors noted a number of radioactive material bags and containers scattered throughout the first two elevations. The inspectors also noted examples of items challenging contaminated area boundaries within the radwaste building which could potentially spread contamination into unposted areas. The RP manager acknowledged the inspectors' observations and indicated that additional attention was warranted in these area The inspectors also noted that the licensee posted the entrances to the reactor building as a radiation area; however, the general area dose rates in the reactor building were generally less than 5 millirem /hr. The inspectors discussed with the RP manager the practice of posting large buildings as radiation areas when only discrete areas within the buildings meet the criteria for a radiation area. As documented in NUREG/CR-5569, l ORNL/TM-1207 (Revision 1), " Health Physics Positions Data Base," the NRC position is that posting practices for a large room or building (e.g., a reactor building) must adequately alert personnel to the presence of radiation areas such that they may minimize exposures they receive. The RP manager indicated that he would review the postings with respect to the radiation levels within the reactor building and to the adequacy of radiologicalinformation for workers. The results of the licensee's review of the posting of the reactor building will be reviewed in a future inspection (IFl 50-331/98007-02).
The inspectors also reviewed the radiological practices of personnel within the RCA and noted that radiation worker practices were acceptable. Personnel properly donned protective clothing. In addition, the inspectors also found that the individuals were knowledgeable of radiological conditions in work areas. However, on April 25,1998, the licensee identified an RP technician at the drywell entrance (a posted radiation and contaminated area) who was inattentive to duty. The technician was responsible for providing RP coverage for work conducted in the drywell and provided support for workers entering the drywell. This was identified when a group of engineers were entering the drywell and observed the technician in a sluggish state. As the RP technician's performance did not meet licensee management's expectations regarding attention to duty, the licensee implemented immediate corrective actions. The RP technician was immediately removed from his post, and the licensee conducted a review of the individual's previous activities. During this review, other personnel indicated that the technician was observed to be in a lethargic state at other times; however, the individuals had not shared this information with licensee management. Prior to the start of the outage, the technician had informed his supervisor thF. he was taking medication that made him drowsy, but the technician did not believe that this would affect his performance. The licensee did not identify any issues concerning the RP technician's previous wor r
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The inspectors found radiological hazards in the facility to be acceptably controlled and l posted. Personnel were knowledgeable of radiological conditions and requirement However, the licensee identified an RP technician who was inattentive to duty. In addition, the inspectors observed radiological housekeeping problems in the reactor drywell and the radwaste building which challenged effective contamination contro R1.3 Outage Dose Trending (IP 83750)
The inspectors reviewed the RP staff's trending of outage dose goals and the staff's ability to identify evolutions which were not progressing as expected or planne Periodically, the RP staff reviewed the accumulated radiation work permit (RWP) dose and man-hour totals and compared those values to the estimates for each of the significant RWPs. Based on discussions with the staff, the inspectors concluded that the comparisons were not rigorous. Specifically, the RP staff indicated that they visually compared the accumulated values to the goals and estimated if the progress of work appeared consistent with the dose goal, but the staff did not perform rigorous calculations or chart the results of the comparisons. The inspectors observed that the staff also graphically trended the daily accumulated dose for each major project to the estimated dose (based on the outage schedule) and observed that outage dose appeared to be well within the estimated goals. The inspectors noted that the licensee included dose planned for contingencies within the graphical representation of the dose goals. However, if the contingencies had not been necessary, the practice of including the contingency dose with the goal could improperly inflate the dose goal and potentially mask over problems in the progress of an evolution. The RP manager acknowledged the potential problems in this practice and planned to evaluate this in the futur Although the RP staff's trending methods were not always systematic, the inspectors concluded that the staff maintained effective oversight of accumulated dos R1.4 Radiological Planning and Controls for Work in the Torus Insoection Scoce (IP 83750)
The inspectors reviewed the licensee's radiological planning and controls for the removal and replacement of the suction strainers in the torus and for the repair of torus coatings. Specifically, the inspectors reviewed the ALARA (as-low-as-is-reasonably- l
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achievable) Review (No.98-006), RWPs (Nos. 50380 and 50580), and RP logs; discussed the evolution with members of the RP staff; and observed the ecsnduct of the evolutio Observations and Findings During the refueling outage, the licensee was performing a replacement of the emergency core cooling system suction strainers in the torus. As part of the evolution, l the staff also evaluated the torus coatings and replaced / repaired any coatings which
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were found to be degraded. The RP staff prepared a common ALARA Review for both
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phases of the evolution and specific RWPs for each phase of the evolution. Based on work estimates and work area dose rates, the licensee prepared a dose goal of about 34 rem for the two evolutions. At the time of the inspection, the dose for the evolution l was about 19 rem and was expected to be completed within the dose goa The inspectors reviewed the RP staff's planning for the evolution and compared the )
licensee's controls with NRC guidance concerning the control of divers in HRA {
Specifically, Regulatory Guide 8.38 " Control of Access to High and Very High Radiatio Areas in Nuclear Power Plants," dated June 1993, and NRC Information Notice 97-68,
" Loss of Control of Diver in a Spent Storage Pool," dated September 3,1997, contain guidance to ensure that radiological controls for diving are adequate to reduce the potential for unplanned personnel doses and overexposure. Consistent with NRC guidance, the licensee implemented a specific procedure (HPP 3104.07 (Revision 3),
" Diving Operations within Radiological Areas") and specific RWPs to control diving evolutions. In addition, the inspectors noted that the licensee performed underwater surveys of the torus to ensure that the area dose rates were well known. However, based on discussions with the RP staff and on the content of the ALARA Review and RWPs, the inspectors concluded that the licensee did not fully consider the recommendations in generic NRC communications concerning diving evolutions in HRAs. Specifically, the inspectors identified the following weaknesses in the radiological planning and controls:
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During the removal of sludge from the torus, the RP staff anticipated a significant radiation source via the filtration units which were stored underwater within the j torus proper. In the ALARA Review, the licensee estimated radiation levels near '
the filtration units to approach 5 to 8 rem per hour (rem /hr) on contact and 1.5 to 2.1 rem /hr at 30 centimeters (re.1996 survey results). At the time of the inspection, the RP staff had measured radiation levels of 4-6 rem /hr on contact with the units and 0.6 - 0.8 rem /hr at 30 centimeters from the units. However, the inspectors identified that the RP staff had not considered the implementation of specific postings or barriers to alert divers to the high radiation levels and/or to prevent the divers from inadvertently coming too close to the units, as recommended by Regulatory Guide 8.38. The ALARA Review recommended that the filtration units be moved when divers were working in the affected storage bays; however, the staff did not move the unit .
The inspectors also identified some problems concerning the RP staff's surveillance of the divers' activities. The diving team maintained continuous communications with the divers and reported changes in location to the RP technicians. However, the RP technicians did not maintain visual contact of the divers, as recommended in Regulatory Guide 8.38 and Information Notice 97-6 At the time of the inspection, the inspectors observed that the RP technicians were knowledgeable of the divers' general locations but did not maintain visual contact of the divers throughout the evolution to ensure the divers' proximity to the underwater radiation sources.
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The initial revisions of the ALARA Review and RWPs (between April 4,1998, and April 11,1998) required continuous monitoring (i.e., remote dosimetry) to ensure that the divers' accumulated doses and dose rates were adequately controlled, consistent with the recommendations of Regulatory Guide 8.3 However, the inspectors observed that the RP technicians did not configure the vamote dosimetry system to provide continuous transmission from the divers'
EDs to the receiving unit. Once a diver submerged in the torus, the dosimetry unit lost contact with the remote monitoring station. Although the diver's ED accumulated the dose information, the RP technicians were unable to continuously monitor the divers' dose and dose rates, and the divers were unable to hear any ED alarms or to view the ED outpu The RP staff indicated to the inspectors that they had not maintained continuous remote monitoring since the beginning of the diving evolution (on about April 7, 1998). In place of the continuous monitoring capability, the RP technicians indicated that stay times were implemented. Based on the anticipated radiation levels in a particular area, an RP technician determined a stay time (about 30 to 120 minutes) and required the diver to resurface at that time interval so that the remote dosimetry unit could update the diver's accumulated informatio Although the use of stay times was an adequate means of controlling exposures, the lack of continuous monitoring limited the ability of the RP staff to ensure that workers were not in close proximity with the filter units (described above) or with other unexpected dose rate areas. In addition, between April 7 and 11,1998, ,
the divers' RWPs (50380 job step 6 (Revision 6 and 7) and 50580 job step 5 (Revisions 0,1, and 2)) stated that if the ability to monitor dose rates was lost, work would be stopped until monitoring could be reestablished. Based on the inspectors' discussions with the RP staff, the staff did not maintain continuous monitoring but did not stop the evolutio Technical Specification (TS) 6.9.1 requires that procedures for personnel RP be adhered to for all operations involving personnel radiation exposure. Procedure ACP 1411.22 requires that personnel entering radiation areas and HRAs obtain an RWP, review the RWP, and follow instructions / requirements set forth. The failure of the staff to comply with the instructions contained in RWP 50380 Job Step 6 (Revisions 6 and 7) (i.e., if the ability to monitor dose rates is lost, to stop work until monitoring can be reestablished) is a violation of TS 6. (VIO 50-331/98007-03).
On April 11,1998, the RP staff revised the RWPs to allow the use of stay times I as an attemate to continuous remote monitoring. Although the change in the RWPs corrected the issue, the RP staff substantially reduced its control of the evolution. For example, the inspectors identified at least one instance when a diver received an ED dose rate alarm (i.e., dose rate of about 0.850 rem /hr)
attributed to working too close to the above filtration units. During the inspection, j the inspectors also observed a diver working near one of the filtration units, with '
no direct RP coverage or monitoring. To address these weaknesses, the RP
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staff revised the RWPs to include a provision that divers were not to be within 4 feet of the filtration unit The inspectors also reviewed the RP logs of torus events and identified a problem l conceming the radiological postings within the torus. Prior to April 10,1998, the RP staff posted the torus room as a radiation area and a contamination area. However, the inspectors identified that the licensee did not adequately post the torus when the filtration units were found to create an HRA within the torus. Specifically, on April 8, 1998, an RP technician measured radiation levels of 4 to 6 rem /hr at contact and 0.6 to l 0.8 rem /hr at 30 cm from the filtration units but did not post the area as an HRA. As the licensee had provided access for the divers, the torus area was accessible to personne However, the RP technicians incorrectly believed that an HRA posting was not necessary since they were in attendance when divers were entering the torus. On April 10,1998, a contract RP supervisor noted the discrepancy between the measured levels and the lack of an HRA posting, questioned the RP manager as to how the torus was to be posted, and directed the technicians to post the ladders into the torus as an HR Although the contract RP supervisor corrected the immediate problem, the individual did not inform licensee management of the problem and did not initiate an action request to identify the root caus CFR 20.1902(b) requires that the licensee shall post each HRA with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, HIGH RADIATION AREA" OR " DANGER, HIGH RADIATION AREA." As defined in 10 CFR Part 20, an HRA is an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.1 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source or from any surface that the radiation penetrates. The failure to properly post the torus as an HRA is a violation of 10 CFR 20.1902(b)
(VIO 50-331/98007-04).
The inspectors discussed the above weaknesses in radiological controls with the RP manager, who indicated that management oversight of the project did not meet expectations. Although the inspectors acknowledged that the level of radiation sources in the torus were not equivalent to those in a spent fuel storage pool, the inspectors concluded that the licensee's radiological controls were not rigorous and that the licensee had not fully evaluated NRC generic communications concerning the control of diving evolutions to prevent unnecessary exposures from underwater radiation source Conclusions Two violations were identified concerning the failure to properly adhere to radiation work permit requirements and the failure to properly post the torus as an HRA. In addition, the inspectors identified weaknesses in the radiological controls and planning of the torus diving evolutions. Although no unexpected personnel doses were observed, the RP staff did not fully consider or evaluate NRC generic communications concerning controls and barriers to prevent divers from receiving unplanned exposures from underwater radiation source _ _ - _ - _ _ . - _ _ _ _ - _ _ _ _ _ - _ - - _ _ _ - _ _ - _ _ _ .
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R1.5 Radiological Planning for the Installation and Removal of Shielding (IP 83750)
l The inspectors reviewed the RP staff's ALARA Review for the installation and removal
! of shielding. The inspectors noted that the review properly addressed anticipated radiological conditions, the use of mock-up training, and contamination control issue During the ALARA Review and RWP preparation, the RP planner had assembled the results and critiques of shielding performed in previous outages. Based on this documentation, the inspectors verified that the ALARA Review effectively incorporated those lessons learned. The inspectors concluded that the planning for the installation and removal of shielding properly addressed radiological control R4 Staff Knowledge and Performance in RP&C R Unauthorized Entry into a Hiah Radiation Area (HRA) Insoection Scoce (IP 8375D)
The inspectors reviewed an incident concerning an entry into a locked HRA by two workers who were not on the proper RWP and were not properly briefed by RP personnel. The inspectors reviewed the licensee's investigation, interviewed the two workers and RP representatives, and reviewed the following procedures:
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ACP 1411.22 (Revision 6), " Control of Access to Radiological Areas," and
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HPP 3104.01 (Revision 11)," Control of Access to High Radiation Areas." Observations and Findings On April 1,1998, two workers entered a locked HRA on the 780' elevation of the turbine building to move equipment into the area. Initially, two different workers were assigned to the evolution; however, the work foreman reassigned the individuals based on resource needs. The foreman had attended an RP pre-job briefing; however, neither of ;
the work crews had been in attendance. Since the workers did not recognize the I requirements, the workers proceeded to the area to conduct the work. After asking the two workers if they were the individuals for the job and the workers responding that they were, an RP technician assumed that the workers were properly briefed and on the correct RWP, and allowed the workers to enter the HRA. While within the HRA, the RP ]
technician provided coverage for the workers and informed the workers of area dose rates. After the workers exited, the workers noted that they had received ED dose rate alarms and reported to the RP staff. In reviewing the workers' RWP requirements, the RP staff identified that the workers were not on the proper RWP for entry into the HR ;
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Although the workers received dose rate alarms of 50 and 59 millirem per hour, the workers exposures of 6 and 10 millirem were below the RWP dose alarm of 25 millire The inspectors reviewed the licensee's investigation of the event, which was thorough and identified the following problems concerning the evolution:
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The two workers performed the work under RWP 52 Job Step 1, " Routine Work
& Inspections in ras," dated January 2,1998. However, the licensee identified that this RWP did not allow entries into HRA .
Prior to entry, the two workers had not obtained a pre-job briefing with RP staff, as required by procedure ACP 1411.22. Although the RP technician had instructed the workers on significant dose rates in the area, the workers were not fully briefed as required by the procedures, and the briefing was not conducted ;
prior to the workers entering the HRA. In addition, the licensee noted that the initial crew that was assigned to the evolution also was not briefed by the RP l staf .
The RP technician who covered the evolution failed to ensure that the workers were properly prepared for the job and were authorized to enter the HRA. Based on poor communications between technicians, the RP technician believed that the workers were briefed by another RP technician. Therefore, the technician i did not question the workers before allowing entry into the HR l The inspectors discussed the incident with the workers and the RP technician and did l not identify any discrepancies between their account of the incident and the results of I the licensee's investigation. Based on the inspectors' review, a lack of adequate communications, questioning attitude, and self checking contributed to the incident. As immediate corrective actions, the licensee discussed the event with the turbine group and the RP technicians prior to any additional locked HRA entries, and the licensee was planning to address long term corrective action j Technical Specification 6.9.1 requires that procedures for personnel RP be adhered to for all operations involving personnel radiation exposures. The failure of the two I workers to follow the requirements of the RWP in accordance with procedure ACP 1411.22 is an example of a violation of TS 6.9.1 (VIO 50-331/98007-05a). In addition, j the failure of the two workers to obtain a briefing with RP prior to entering the HRA in )
accordance with procedure ACP 1411.22 is another example of a violation of TS 6. (VIO 50-331/98007-05b).
The inspectors also noted that the failure to adhere to an RWP was the subject of a previous Notice of Violation documented in NRC Inspection Report No. 50-331/97002 (DRS), which was also attributed to weaknesses in communications between work groups. Since the corrective actions for that violation were not effective in preventing the above violation, enforcement discretion has not been exercise fanclusions Two examples of a violation were identified concerning the failure of two workers to properly adhere to RP controls for entry into an HRA. Although the licensee's review of the incident was thorough, the violation was similar to a previous NRC Notice of l Violation for not adhering to RP work instructions. The inspectors observed that l
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problems in communications, worker performance, and RP technician oversight contributed to the inciden R4.2 Inadeauate Use of Electronic Dosimeters (EDs)
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The inspectors reviewed a number of incidents in which workers had entered the RCA without EDs or with inactive EDs. The inspectors discussed the incidents with the RP manager and reviewed the action request for each inciden Observations a.nd Findinas The inspectors reviewed the licensee's requirements conceming personnel access to radiological areas and dosimetry. Procedure ACP 1411.22 (Revision 6), " Control of Access to Radiological Areas," requires, in part, that personnel entering radiation areas and HRAs obtain an RWP number from the RP staff and comply with the instructions i listed on the RWP. In the case of entry into HRAs, procedure ACP 1411.22 specifically requires that personnel wear EDs. Procedure ACP 1411.18 (Revision 10)," Personnel Dosimetry," requires that radiation workers, while in the restricted or controlled area, wear dosimetry in the manner required by the RW Between April 4 and 14,1998, the licensee documented the following instances in which workers entered the RCA without EDs or with EDs which had not been activated:
- On April 4,1998, a member of the operations staff entered the drywell (a posted HRA) with the operations manager to hang and verify equipment tags. The individual was performing the entry under RWP No. 40010 Job Step 6 (Revision 3), which required the user to wear an ED and to monitor the ED. Although the individual was given an ED for the entry, the individual mistakenly did not activate the ED. In addition, an RP technician issued the ED and verified that the individual was wearing the ED, but the technician did not notice that the ED was not activated. Upon exiting the drywell, the individual reported to the RP staff that his ED was inactive. Based on the operations manager's dose, the licensee assigned the individual a dose of 5 millirem for the evolutio Technical Specification 6.9.1 requires that procedures for personnel RP be adhered to for all operations involving personnel radiation exposures. The failure of the individual to wear an active ED as required by the RWP is an example of a l violation of TS 6.9.1 (VIO 50-331/98007-06a). l
. On April 5,6, and 8,1998, three incidents occurred in which individuals signed j onto an RWP and activated an ED; however, the individuals left the active ED at '
the access control area and either entered the RCA with an inactive ED from the storage rack or entered the RCA without an ED. The RWPs that the individuals'
were assigned to (i.e., RWP Nos. 33 Job Step 1 (Revision 4),53 Job Step 1 (Revision 6), and 10230 Job Step 1 (Revision 6)) required the individuals to wear
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EDs. In each case, the individual was in the reactor building (a posted radiation area) for less than 5 minutes, was located by RP personnel, and returned to access control. The licensee determined that the individuals' doses were each less than 1 millire Technk,al Specification R9.1 requires that procedures for personnel RP be adhered to for all operations involving personnel radiation exposure. The failurc of the three individuals to wear active EDs in accordance with RWP requirements is an example of a violation of TS 6.9.1 (VIO 50-331/98007-06b).
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On April 8,1998, an iridividual exited the reactor drywell area and signed-off of the applicable RWP for that activity. The worker exited the reactor building under RWP No.10051 Job Step 1 (Revision 3), which required the worker to wear an ED. However, the individual failed to sign onto the RWP and exited the area without an ED, The individual was in the reactor building (a posted radiation area) for a limited amount of time (traversing from the drywell access area to the RCA access control area). Based on the individual's limited time without an ED, the licensee determined that the individual's dose was less than 1 millire Technical Specification 6.9.1 requires that procedures for personnel RP be l adhered to for all operations involving personnel radiation exposure. The failure of the individual to wear active EDs in accordance with the RWP requirements is an example of a violation of TS 6 9.1 (VIO 50-331/98007 06c).
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On April 14,1998, two individuals entered the RCA from the turbine building, but the individuals made the entry without an RWP. The two workers entered areas !
of the turbine building (a posted radioactive materials area) and of the reactor !
building (a posted radiation area) to obtain tools from a tool storage area. Based l on the individuals' limited time in the RCA and work areas, the licensee !
determined that the individuals' doses were less than 1 millire Technical Specification 6.9.1 requires that procedures for personnel RP be l
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adhered to for all operations involving personnel radiation exposures. The failure of the two individuals to obtain an RWP and obey the requirements of the RWP as required by ACP 1411.22 is an example of a violation of TS 6. (VIO 50-331/98007-06d).
Following each incident, the RP staff performed a review of the circumstances, l determined an estimated dose for the entry, and counseled the individual invoived. The inspectors reviewed the licensee's dose determinations and did not identify any problems or unplanned exposure Although personnel error and failure to self-check were root causes of all of the above incidents, the licensee also attributed the incidents to the absence of a device which had been installed to electronically validate each individual's ED. Prior to an individual leaving access control and entering the RCA, the individual had to place his/her ED into
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the device which ensured that the ED was properly activated and opened an entrance ,
gate to the RCA . During March and early April of 1998, the device was being repaired !
by the vendor, following a licensee-identified problem with the mechanism. At that time, the licensee did not implement any measures to compensate for the missing devic l Based on discussions with licensee management, the licensee planned to implement compensatory measures if the device was out-of-service in the futur The inspectors noted that the failure to adhere to an RWP was the subject of a previous l Notice of Violation documented in NRC Inspection Report No. 50-331/9"02(DRS). In addition, NRC Inspection Repor1 No. 50-331/97013(DRS) contained a non-cited violation concerning similar ir cidents (i.e., individuals who had entered the RCA without EDs). Since these violations wero similar to the recent incidents and since corrective actions for the earlier violations were not effective in preventing the recent incidents, enforcement discretion has not been exercise I Conclusions .
I Four examples of a violation of station procedures were identified concerning incidents in which personnel cntered radiation areds and HRAs within the RCA but did not have the proper dosimetry. The licensee identified and documented six incidents in which individuals had entered radiological areas with either inactivated EDs or without ED l Although the licensee performed adequate assessments of worker doses, the incidents I indicated a lack of personnel attention to RP requirements. In addition, corrective l actions for a similar, previous non-cited violation were not adequate to prevent these incident R8 Miscellaneous RP&C lssues R8.1 (Closed) Unresolved item (URI) No. 50-331/97013-02(a): The licensee did not appear to be training chemistry technicians on the post accident sampling system (PASS) at the 2-year frequency committed to the NRC, and the licensee was unable to produce records which indicated that chemistry technicians were receiving the trainin Following the inspection, the licensee recognized that the chemistry technicians were to be trained at a 2-year frequency and implemented revision 9 to procedure PCP 1.2,
"DAEC Chemistry Quality Control Program," to include a requirement for PASS trainin Procedure PCP 1.2 required each chemistry technician to perform PASS surveillance test procedures at least once every 2 years to remain qualified on the PASS, which fulfilled the licensees NUREG 0737 commitments to the NRC. During this inspection, the inspectors reviewed the licensees training records which were maintained in a laboratory notebook and identified some lapses in technician training. The inspectors identified that three chemistry technicians had not performed the PASS surveillance test procedures for over 2 years (i.e., the last performance dates for these technicians were June 12,1905, November 17,1995, and November 21,1995, respectively). However, the inspectors noted that the chemistry staff had not disqualified the individuals from the task and that chemistry management was unaware of the lapse in training. Following the identification of the issue, the licensee acknowledged the deficiency and disqualified the three technicians from the PASS qualificatio _-_-__- .-- -- -
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Technical Specification 6.4.1 requires that a training program be established to maintain the overall proficiency of the operating organization, which consists of both retraining and replacement training elements and meet or exceed the minimum provisions outlined in ANSI /ANS 3.1-1978. Section 5.1 of ANSI /ANS 3.1-1978 requires, in part, that a continuing training program be used for requalification training necessary to ensure that personnel remain proficient. The failure of three chemistry technicians to perform PASS surveillance tests in accordance with procedure PCP 1.2 to maintain proficiency is a violation of TS 6.4.1 (VIO 50-331/98007-07).
The inspectors also identified some problems concerning the conduct of the PASS training. For example, the licensee's NUREG 0737 commitment to the NRC (NRC Inspection Report No. 50-331/97013(DRS)) indicated that formal training was to be conducted. The chemistry supervisor indicated that the technicians performed the surveillance but that the performance was not observed or critiqued to identify any deficiencies. The chemistry staff concluded that the performance was successfulif the technician obtained a sample; however, the staff did not confirm the validity of the sample. The inspectors questioned the adequacy of unobserved performances of the surveillance as compared to formal training, which routinely consists of instruction and evaluation. As part of the corrective actions for the above violation, the licensee planned to review the conduct of the training evaluations and the tracking of PASS training requirement This URI is close R8.2 (Closed) URI No. 50-331/97013-02(b): The licensee was to provide formal training procedures to satisfy the requirements of TS 6.8.1.12 which required, in part, that written procedures be prepared covering the program to ensure the capability to accurately determine airborne iodine concentrations in vital areas under accident conditions, including training of personnel. At the time of this inspection, the inspectors reviewed Instructor Guide (Revision 1), " Fundamental Job Coverage, 30037," and Instructor Guide (Revision 3), " Emergency Response for Health Physics Technicians, 30043." The inspectors noted that these training guides addressed air sampling during accident conditions. Specifically, the guides provided instruction in obtaining and analyzing airborne iodine samples both within and outside of the facility during accidents. This item is close R8.3 (Ocen) URI No. 50-331/97008-03: Since the licensee was unable to obtain a representative containment atmosphere sample via the PASS for iodine quantification, the inspectors and licensee were to review licensing documents to determine if the licensee had the capability required by TS 6.8.1.12 to determine airborne iodine concentrations in vital areas. At the time of this ir,spection, the licensee and inspectors reviewed the licensing basis for TS 6.8.1.12 and concluded that the TS referred to the capability to accurately determine airborne iodine concentrations within the plan Specifically, the requirement focusses on areas accessed by accident and repair teams and emergency responders during accidents (NUREG 0578). The inspectors concluded that this capability existed via, routine RP survey procedures, the availability of air i sampling equipment, and the training of RP technicians described in Section R '
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The inspectors noted, however, that the licensee did not have any capability other than the PASS to accurately sample and measure the concentration of iodine within the containment atmosphere. Section 12.3.4 of the licensee's Updated Final Safety Analysis Report (UFSAR) states that the licensee has the capability to obtain representative samples of the containment atmosphere and to determine the iodine concentration of these samples. Section 12.3.4 also states that the PASS gas lines are heat traced to 250 degrees Fahrenheit to prevent iodine plate-out. As described in NRC Inspection Reports Nos. 50-331/97008(DRS) and 50-331/97013(DRS), the licensee determined in early 1997 that the lack of complete heat tracing of containment
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atmosphere sampling lines resulted in the inabili'.y to obtain a representative containment atmosphere sample via. the PASS for lodine analysis. However, at the time of this inspection, the licensee had not corrected the haat tracing deficiency and had not conducted an adequate evaluation to address the lack of iodine sampling capabilit Following the onsite segment of the inspection, the licensee planned to perform an evaluation to revise the UFSAR and to delete the references to iodine analyses of PASS containment atmosphere samples. The licensee reviewed its NRC commitments concerning NURF.G 0737, the Emergency Plan and implementing procedures, and emergency operating procedures and concluded that the iodine sampling capability was not necessary. In addition, the licensee concluded that the industry recognized, inherent eiror in the atmosphere iodine measurement also reduced its value. The inspectors will review the adequacy of the licensee's evaluation in future NRC inspections.
1 V. Manaaement Meetinas Xi Exit Meeting Summary l
l On April 17,1997, the inspectors presented the inspection results to licensee management.
l The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified which related to inspection finding j l
l On April 29,1998, a teleconference was conducted between the Region 111 staff, the Office of i Nuclear Reactor Regulation staff, and the licensee to discuss the licensee's evaluation and resolution of PASS operability and UFSAR issues (Section R8.3). On May 1,1998, additional ;
information was provided by the licensee for NRC revie i l
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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Eilers Materials Handling Supervisor J. Franz Vice President-Nuclear R. Hite Radiation Protection Manager D. Jantosik Quality Assurance Manager K. Jewett Radiation Protection Specialist / Engineer B.Klotz AR Administrator L. Kriege Chemistry Supervisor B. McVicker Chemistry Foreman R. Murrel Licensing
} R. Perry Health Physics Supervisor K. Putnam Licensing Supervisor K. Ridley Electrical Maintenance Supervisor B. Richmond Health Physics Supervisor C. Rushworth Licensing S. Russel Quality Assurance D. Schebler Quality Assurance R. Schlueter Health Physics Foreman C. Sullivan Systems Engineering G. Van Middlesworth Plant Manager T. Vine Radwaste Supervisor D. Wilson Assistant Vice President INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 92904: Follow-up Plant Support
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ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-331/98007-01 VIO Inadequate evaluation of radiological hazards incident to operational events (Section R1.1).
50-331/98997-02 IFl Radiological postings within the reactor building (Section R1.2). 1 50-331/98007-03 VIO Failure to follow RWP during torus diving (Section R1.4).
50-331/98007-04 VIO Failure to post an HRA within the torus (Section R1.4).
50 331/98007-05(a, b) VIO Failure to adhere to RP procedures (Section R4.1).
50-331/98007-06(a-d) VIO Failure to wear EDs in radiological areas (Section R4.2).
50-331/98007-07 VIO Failure to ensure PASS qualifications of chemistry technicians (Section R8.1).
Closed 50-331/97013-02(a) URI Post accident sampling system training as described in licensee correspondence (Section R8.1).
50-331/97013-02(b) URI Post accident sampling system training as described in licensee requirements (Section R8.2).
Discussed '
l 50-331/97013-03 URI Capability to determine airborne iodine concentration in vital areas under accident conditions (Section R8.3). j l
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LIST OF ACRONYMS USED l ALARA As-Low-As-Is-Reasonably-Achievable l CFR Code of Federal Regulations l DRS Division of Reactor Safety i
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ED Electronic Dosimeter HPP Health Physics Procedure IFl' Inspection Follow-up Item IP Inspection Procedure
! LPCI Low Pressure Core injection NCV Non-cited Violation NRC Nuclear Regulatory Commission PASS Post Accident Sampling System RCA Radiologically Controlled Area RHR Residual Heat Removal RP Radiation Protection RP&C Radiological Protection and Chemistry RWP Radiation Work Permit TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation I l
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DOCUMENTS REVIEWED i Action Requests (ARs) Nos. 980848.00,980849.00,980854.00,980855.00,980858.00, 980857.00, and 981118.00.
l ALARA Reviews Nos.98-003 (Revision 0), " Shielding," and 98-006 (Revisions 0,1,2, and 3),
- MH: Torus Coating /MJ: ECCS Suction Strainer."
Course Title: " Fundamental Job Coverage, 30037," Instructor Guide No. 5 (Revis;on 1).
Course Title: " Emergency Response for Health Physics Technicians,30043," Instructor Guide No.1 (Revision 3).
Procedures No ACP 1411.1 (Revision 8),"The ALARA Emphasis Program;"
ACP 1411.22 (Revision 6)," Control of Access to Radiological Areas;"
ACP 1411.18 (Revision 10), " Personnel Dosimetry;"
HPP 3101.05 (Revision 10)," Administration of Radiation Work Permits (RWPs);"
HPP 3102.02 (Revision 3), "ALARA Job Planning;"
HPP 3103.03 (Revision 9), " Radiological Area Surveillance and Postings;"
HPP 3104.01 (Revision 11), " Control of Access to High Radiation Areas;"
HPP 3104.07 (P.evision 3)," Diving Operations within Radiological Areas;"
HPP 3105.09 (Revision 7), " Personnel Dosimetry for External Exposure;" and PCP (Revision 9), *DAEC Chemistry Quality Control Program."
Duane Arnold Energy Center Survey Form HP-41: Survey Nos. 97-3403,9-3711,98-102,98-740,98-815,98-825,98-826,98-1010,98-1092,98-1101,98-1107,98-1108,98-50011,98-50013,98-50021,98-5022,98-50024, and 98-5002 RWPs No Job Step 7 (Revision 22), " Mechanical Work in HRAs and/or LHRAs;"
33 Job Step 1 (Revision 4), " Management, Planning, Engineering inquiries;"
52 Job Step 1 (Revision 6), " Routine Work & Inspections in ras;"
53 Job Step 1 (Revision 6), " Routine Work & Inspections in Radiological Areas;"
10051 Job Step 1 (Revision 3), " Refuel Outage Routine Work & Inspections in ras;"
10230 Job Step 1 (Revision 7), "M5 - Heat Exchanger & Cooler Maintenance for RFO;"
40070 Job Steps 1-6 (Revision 3),"SL: Shielding in the Drywellin Support of RF015;"
40010 Job Step 6 (Revision 3),"P1: OP Tagouts, Valve Line-Up, and Inspections in Drywell;"
50380 Job Step 6 (Revisions 5,6,7, and 8),"MH: Torus Desludge & Inspect / Repair Project;" and 50580 Job Step 5 (Revisions 0,1,2, and 3),"ECCS Strainer Mod."
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