0CAN079024, Forwards Revised Response to Insp Repts 50-313/90-04 & 50-368/90-04.Corrective Actions:Specific Communication Meetings Will Be Conducted W/Staff Re Decontamination Practices & Procedures

Forwards Revised Response to Insp Repts 50-313/90-04 & 50-368/90-04.Corrective Actions:Specific Communication Meetings Will Be Conducted W/Staff Re Decontamination Practices & Procedures

ML20056A205
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/31/1990
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN079024, CAN79024, NUDOCS 9008060135
Download: ML20056A205 (5)

Text

'

-~_-

Entergy ==~er o - u- u=.

Rue a fox 137G Operat'ons we" ~ m noi b $015 4 3100 July 31, 1990 OCAN079024 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D. C. 20555

$UBJECT: Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Revised Response to Inspection Report 50-313/90-04; 50-368/90-04 Gentlemen:

Pursuant to the provisions of 10CFR2.201, and conversations between the NRC Region IV staff and members of my staff, attached is the revised response to Notice of Violation 313/9004-01; 368/9004-01 concerning the decontamination of a Unit 1 operator. This submittal supercedes the previous response. Revisions to the original response are indicated by side bars in the left margin.

Very tr yours, 1

i E. C. Ewing General Manager, Assessment ECE/JDJ/sgw Attachment cc: Regional Administrator Region IV U.S. Nuclear Regulatory' Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

., n ,,

d. V s i i I-

)

0-llg

1

. U. S. NRC l Attachment  !

. Page 1 July 31, 1990 Notice of Violation 4

A. Technical Specification 6.1.8.a for Units 1 and 2 requires that written procedures shall be established, implemented, and maintained covering activities recommended in Appendix A of Regulatory Guide 1.33. Section 7.3 addresses contamination control.

Paragraph 6.4.2 of the licensee's Procedure 1622.010 requires the initiation of decontamination procedures for contamination of individuals utilizing the guidelines provided in Appendix II, and that any contaminated hair that cannot be decontaminated must be removed.

Contrary to the above, on January 31, 1990, the inspectors determined that hair of an individual which was contaminated with 30 nanocuries of cobalt 58 on December 20, 1989, could not be decontaminated and the ,

hair was not removed.

This is a Severity Level IV violation. (Supplement VI) (313/9004-01; 368/9004-01)

Response to Violation 313/9004-01: 368/9004-01 I

1. Reason for the violatioDi The violation occurred as stated in that a sufficient amount of hair was not removed to conservatively place the individual below established release limits. This event occurred because management '

expectations in this area had not been adequately communicated to the i HP staff.

To facilitate understanding of this incident, the following sequence j of events is given.

On December 18, 1989, an ANO-1 Waste Control Operator (WCO) vas contaminated as a result of a relief valve opening. The WC6 was sprayed with water from the primary system. His hands, fare and the back of his head were contaminated. He was decontaminated to less than 100 net counts per minute in accordance with Personnel Decontamination procedure 1622.010 and cleared a PCM-1B contamination monitor prior to his release. A whole body count the following day indicated a total of 1.4% MPBB (1.2% of which was "Co), which indicated external contamination generalized on the surface of the l upper body. No sigi..ficant internal contamination was indicated.

On December 22, 1989, the WC0 alarmed a PCM-1B upon his exit from the controlled access area at the Unit 1 exit location (CA-1). The Health Physics (HP) technician at CA-1 notified the HP Supervisor on duty and stated that the WC0 had some detectable activity in his hair. The l

l

U. S. NRC Attachment

. Page 2 July 31, 1990 supervisor directed the technician to take the WC0 to CA-2 (controlled access entry location) where he could be frisked in a low background area to determine the extent of contamination. The overall contamination levels in the hair located on the back of the WCO's head were approximately 60 cepm. On a certain section of his hair, when the hair was clumped together, approximately 100 cepm was detected.

This clump of hair was removed. The remaining hair was refrisked.

The highest reading located was approximately 60 cc'am, even when the hair was clumped together. Procedure 1622.010 stated that personnel causing a PCM-1B to alarm and exhibiting greater than or equal to 100 cpm above background are subject to decontamination. As the highest reading was approximately 60 cpm above background, no further decontamination efforts were required by procedure. At?endix 11 of 1622.010 contains guidelines which are to be followed for readings greater than or equal to 100 cepm.

At about 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br /> on January 18, 1990, the Lead Supervisor Health Physics Operations of Louisiana Power and Light Company's Waterford-3 Station (W-3) contacted ANO regarding the WC0 who was visiting W-3 for training. When the ANO WC0 exited the W-3 RCA, he alarmed a PCM-1B.

The alarms were for the head, zone 1, and zone 5. He had previously infornied the W-3 staff of causing similar PCM-1B alarms at ANO. The W-3 Lead Supervisor called to advise us of the W-3 alarm and to ask details of the administrative actions taken at ANO. According to the W-3 Lead Supervisor, the WC0 had stated that he could not consistently clear PCM-1Bs but that subsequent frisker checks failed to locate any contamination. The W-3 Lead Supervisor was advised to prohibit RCA entry by the WC0 until the matter could be fully understood. The WCO's W-3 TLD was pulled and he was restricted to areas outside the RCA for the remainder of his W-3 training.

The WCO's whole body counts from January 20, 1990 (including an exit count on January 16, 1990, in preparation for the trip to W-3 and a count on January 20, 1990, upon his return from W-3), dating back through March 2, 1987, were reviewed. The data confirmed he had not incurred significant internal contamination in this time frame based on the levels of contamination, the isotopes involved, and biological clearance.

I The WC0 was interviewed by the ANO Unit 1 Assistant Manager Operations and an ANO Health Physics Specialist on January 20, 1990. The WC0 stated that he had experienced PCM-1B alarms at ANO approximately fifty percent of the time when he exited the RCA. He stated the repetitive alarms began after the contamination event of December 18, 1989. The alarms were always for the head or upper body. He stated that he had followed procedures each time and had reported to the CA-1 HP technician for frisking or, during backshift when no HP technician was stationed at CA-1, had frisked himself. No contamination was ever l located. It is important to note that no specific individual in the HP organization was aware of the repetitive nature of the alarms.

1

. . U. S. NRC Attachment

. Page 3 July 31, 1990 1

i The WC0 retained the alarm printouts from the PCM-1Bs each time and compared them to assure himself the reported activity was not increasing. An increase in activity would have indicated that additional radioactive material had been received during an RCA entry.

The reported activity was characterized as " barely over the alarm setpoint." Although the activity reported by the PCM-1Bs was gradually decreasing, the WC0 showed the alarm printouts to an HP Trainer as a matter of general curiosity. Together, they briefly reviewed the data and the trainer confirmed that only small amounts of activity were involved and that there was no need for concern since the activity was presumably a residual from the December 18, 1989, event and was chemically bound to the hair and skin. They planned to do a detailed investigation later in January to try to locate and remove the activity. Being thus assured of the lack of significance of the alarms, the WC0 disposed of the printouts. ,

The Unit 1 Assistant Manager Operations and Health Physics Specialist accompanied the WC0 to the Controlled Access exit location to witness the PCM-1B response first hand. The W-3 and ANO PCM-1Bs are set to alarm at the same activity (5000 DPM/100 cm'); therefore, comparing PCM-1B response from the two installations is valid. The WC0 caused four alarms out of eight PCM-1B checks. The alarms were always for the head and/or upper body. These were the same areas which alarmed at W-3. Three of the four alarms were generated on a PCM-1B which printed the alarm activity. One of the alarms was from activity less than 1% above the alarm limit (5 cpm above the alarm limit). The l highest limit (59ofcpm the greater three was thanfrom measured the alarm limit).activity 9% above Dispersed externalthe alarm activity of this low inagnitude is consistent with the whole body count l data and with the PCM-1B repetitive alarms.

2. Corrective steos taken and the results achieved:

i An event of this nature is not consistent with ANO current philosophy and policy of conservative operations. Proper conservatism in decontamination practices and procedures that will prevent recurrence of such an incident has been communicated via memorandum to the HP staff. ,

The following additional actions have been taken:

. The CA-1 exit point has been staffed with an HP technician 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This will eliminate the necessity for personnel alarming the PCM-1B during off hours to perform self-frisking.

• A tracking program has been established to identify repetitive i PCM-1B alarms associated with previously contaminated individuals.

This process will continue to be evaluated to ensure effective tracking of repetitive alarms.

L

U. S. NRC i Attachment Page 4 ,

July 31, 1990 e Communicating the responsibility of the HP department to the HP staff has been initiated regarding indications of dispersed activity of a low magnitude as it relates to skin contamination and the course of action to be followed. Emphasis is being placed on the shielding /n,asking effects that can occur if an individual's skin or hair is not completely dried before surveying (a suspected contributing factor to the event cited in this violation), dead ,

rones associated with monitoring equipment, proper survey techniques, procedural compliance, and notification and involvement of the HP supervisors. *

3. Corrective stens that will be taken to orevent recurrenen i Specific communication meetings will be conducted with the HP staff.

The purpose of these meetings will be to convey management's expectations regarding AN0's current philosophy and policy of conservative operations regarding decontamination practices and procedures. Additionally, a memorandum summarizing management's expectations for each ANO employee will be distributed to ANO l personnel. These actions will be completed by August 31, 1990.

4. Date of full como11ance:

Compliance was achieved with the issuance of the memorandum communicating the policy to the HP staff, the posting of a 24-hour HP technician at CA-1, and implementation of the tracking program. Full compliance will be completed by August 31, 1990, pending completion of the specific communication meetings with the HP staff, I

l I

l l

l

I DAV!9-BESSE  !

HED DISCREPANT COMPONENT LISTING PASE NO: S  :

,_HED_NQ 51028 i ms PANEL _ID.: C5715 (Cont'd)

SPECIAL '

COMPONENT IDENTIFICATION STUDY El 6210 SU XFMR O2 TO BU3 B A-C KILOVOLTS DISP El 6256 A BUS KILOVOLTS DISP >

El 6257 BUS KILOVOLTS DISP El 6271 DC VOLTS (D1P) DISP i El 6272 DC VOLTS (D2N) DISP l El 6275 DC VOLTS (DIN) DISP t El 6276 DC VOLTS (D2P) DISP ,

El 6277 AC VOLTS (Y1) DISP  !

El 627B AC VOLTS (Y4) DISP  !

El 6279 AC VOLTS (YAR) DISP  ?

El 6280 AC VOLTS (YBR) DISP +

El 62B1 AC VOLTS (Y3) DISP (

El 6282 AC VOLTS (Y2) DISP +

El 6297 AC VOLTS (YAU) DISP El 6298 AC VOLTS (YBU) DISP

!! 6200 AUX XFMR 11 TO BUS A A-C AMPERES DISP 11 6201 SU XFMR TO BUS A A-C AMPERES DISP 11 6203 SU XFMR 01 TO BUS A A-C AMPERES DISP

!! 6204 BUS A TO XFMR AE4 A-C AMPERES DISP  !

!! 6205A BUS A TO XFMR AE3 A-C AMPERES DISP BUS A TO XFMR AF3 A-C AMPERES DISP (g 3)11I 6205B 6206A BUS A TO XFMR AE2 A-C AMPERES DISP '

11 62060 BUS A TO XFMR AF2 A-C AMPERES DISP 11 6200 AUX XFMR 11 TO BUS B A-C AMPERES DISP i  !! 6209 SU XFMR 01 TO BUS B A-C AMPERES DISP l  !! 6210 SU XFMR O2 TO BUS B A-C AMPERES DISP 11 6211 BUS B TO XFMR BF4 DISP 11 6212A BUS B TO XFMR BF2 A-C AMPERES DISP ,

31 6212B BUS B TO XFMR BE2 A-C AMPERES DISP 11 6213A BUS B TO XFMR BF3 A-C AMPERES DISP i 11 62130 BUS A TO XFMR BE3 A-C AMPERES DISP 11 6260 BUS C2 LOAD A-C AMPERES DISP

!! 6262 BUS C1 LOAD A-C AMPERES DISP 11 6263 BUS D1 LOAD A-C AMPERES DISP 11 6289 BATTERY IP DISCH CHG D-C AMPERES DISP 4 11 6290 BATTERY 2N DISCH CHG D-C AMPERES DISP 11 6291 BATTERY IN DISCH CHG D-C AMPERES DISP 11 6292 BATTERY 2P DISCH CHG D-C AMPERES DISP 11 6894 BUS A TO XFMR AE6 A-C AMPERES DISP-11 6896 BUS B TO XFMR XF6 DISP S1 6222 RPM DG-1 SPEED DISP SI 6223 RPM DG-2 SPEED DISP XI 6221 HERTZ DISP XI 6231 HERTZ DISP PANEL 1Q: C5716 OMPONENT IDENTIFICATION FI 1535 CS PMP 2 DISCH FLOW DISP

--