IR 05000313/1981023
| ML20030C295 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/17/1981 |
| From: | Brown G, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20030C285 | List: |
| References | |
| 50-313-81-23, 50-368-81-22, NUDOCS 8108250619 | |
| Download: ML20030C295 (9) | |
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I' i j U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement ' Region IV i j Reports: 50-313/81-23 Licenses: DPR-51
50-368/81-22 NPF-6
' Dockets: 50-313 50-368 ! Licensee: Arkansas Power and Light Company (AP&L) P. O. Box 551 ! Little Rock, AR 72203 , Facility Name: Arkansas Nuclear One (AND) Inspection At: Russellville, AR Inspection Conducted: July 20-24, 1981 , i Inspector: /kb [/ M l/ [[/7/h/ ! i BlaineMurray,' Chief,(/cilitiesRadiation 06te ' { Protection Section
i Approved by: '1/y4fM /7f , f4 D. Brown ~, Chief ~,'lechnical Inspection Branch D e l ' Inspection Summary: Inspection on July 20-24, 1981 (Reports: 50-313/81-23 and 50-368/81-22)
Areas Inspected: Follow-up action on items identified during the Health l Physics Appraisal (Reports 50-313/80-20 and 50-368/80-20) and the Radiation i Protection Program including staffing, training programs, audits, and j instrumentation QA/QC programs.
The inspection involved 33 onsite j inspector-hours by one NRC inspector.
! Results: No violations or deviations were identified.
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0108250619 810818h i PDR ADOCK 05000313 O s PDR
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DETAILS l 1.
Persons Contacted (AF&L) J. P. O'Hanlon, ANO General Manager
- L. J. Dugger, Special Projects Manager
- M. J. Dolanis, Health Physics Superintendent and Radiation Protection Manager (RPM)
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- D. D. Snellings, Technical Assistant Superintendent
' J. D. Vandergrift, Training and Counseling Supervisor D. J. Wagner, Health Physics Supervisor R. E. Green, Health Physics Supervisor r A. E. Murray, Health Physics Supervisor B. C. Burchard, Health Physics Supervisor
- M. Cooper, QA Engineer
- D. Provencher, QA Engineer I. L, Mosquito, Training Coordinator
- Denotes those present during the exit interview on July 24, 1981.
The inspector also interviewed other technicians and administrative personnel.
2.
Licensee Action On Previous Inspection Findings (0 pen) Severity Level IV violation - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Procedures: The licensee is currently in the process of revising and/or developing new procedures to ensure compliance with 10 CFR 20 requirement.
The licensee has committed to an October 1, 1981, completion date.
This item remains open pending implementation of the procedures.
(Closed) Severity Level IV violation - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Transportation: The licensee has revised their radioactive shipping procedures to correct the violation.
This item is considered (losed.
(Closed) Severity Level IV violation - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Containers: The licensee has revised their procedures covering radioactive containers to correct the violation.
Th.s item is considered closed.
(0 pen) Significant Weakness - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Engineering Controls: The licensee has initiated a program to correct the problems associated with airborne releases in the Unit 1 auxiliary building.
This item is considered open pending completion of the plant modifications.
(See Section 7 of this report).
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(Closed) Significant Weakness - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Health Physics Organization: The licensee has changed the plant organization to be in agreement with the commitments in their April 16, 1981, letter.
This item is considered closed.
(See Section 4 of this report).
(0 pen) Significant Weakness - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Health Physics Shift Coverage: The licensee has committed to provided ANSI N18.1 qualified health physics technicians on the off-shifts by July 1, 1982.
This item is considered open pending implementation of this commitment.
(0 pen) Sigificant Weakness - Health Physics Appraisal Report 50-313/80-20 and 50-368/80-20, Radioactive Waste: The licensee has initiated changes to their procedures to correct the problems identified in the appraisel report.
Implementation for these changes is scheduled for September 1, 1981.
This item is considered open pending completion of the scheduled corrective action.
3.
Open Items Identified During This Inspection a.
Health Physics Training (81/22-01) A written program had not been completed for initial training and retraining of the health physics staff.
(See Section 6 of this report).
b.
Job Descriptions (81/22-02) Job / Position description had not been completed for health physics personnel.
(See Section 8 of this report).
c.
Instrument Calibration (81/22-03) A calibration program, including full range calibrations, had not been established for the whole body counter, neutron, and beta survey meters.
(See Section 9 of this report.). d.
Instrun ent Field Test (81/22-04) A program had not been established to field test survey meters prior to each use.
(See Section 10 of this report).
e.
Evaluation of Contractor Personnel (81/22-04) A procedure had not been developed to provide direction and guidance regarding a uniform program for evaluating prospective contractor health physics technicians.
(See Section 11 of this report).
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Health Physics Organization i The Health Physics Appraisal Team had expressed concerns regarding the location of the Radiation Protection Manager (RPM) within the licensee's
organizaticn.
The Health Physics Superintendent (HP3) is designated as the RPM.
The Appraisal Team noted that the RPM was separated from the General Manager by two intervening supervisory levels and the RPM position was not on an equal level with other Department Heads.
. In response to the Appraisal Team findings, the licensee has revised their
organization and elevated the Health Physics Department to a level comparable with operations and maintenance.
The previous title of Health Physics
Supervisor has been changed to Health Physics Superintendent.
Under the revised organization, the Health Physics Superintendent reports to the i Manager, Engineering and Technical Support who in turn reports to the ANO
General Manager. The RPM has direct access to the ANO General Manager in matters relating to radiological health and safety.
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The licensee has also established the position of Corporate Health Physicist . to provide support and coordination for the onsite health physics organization.
The onsite Technical Analysis Superintendent has been selected to fill the Corporate Health Physicist position.
This position will be effective in mid-August, 1981.
No violations or deviations were identified.
5.
Staffing l j The licensee has increased their health physics staff since the appraisal.
One new Health Physics Supervisor position has been established for a i total of five supervisors.
Positions for two Radiological Engineers
have been approved, but tnese two positions had not been filled.
Ten Health l Physics Technicians had recently completed the licensee in-house training
program and were assigned to the Department for routine health physics i duties.
The Health Physics Department has 28 approved technician positions.
At j the time of this inspection, 22 of the 28 positions were filled.
A request had been submitted for 12 new technician nositions for a planned l total of 36.
It was noted that with the increase of licensee technicians, less reliance was being placed on contractor health physics personnel.
' ! No violations or deviations were identified.
6.
Training
The inspector reviewed the initial training and retraining programs for the i Health Physics Department. Written training programs, including defined , i goals, objectives, schedules and a method to evaluate the effectiveness l of training, had not been established for either initial or retraining.
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A group of 10 technician completed an initial training program in February 1981.
This program was designed to hire individuals without prior health physics experience and provide the necessary training through an in-house program.
The training course consists of 12 weeks at a fossil unit covering electrical generation followed by an eight week sc.gment on health physics fundamentals conducted by an offsite con-tractor. Af ter completion of the formal classroom training, the technicians were assigned to the Health Physics Department for departmental on-the-job training (0JT).
The responsibility for supervising the training program appeared to be fragmented between the corporate office, the onsite training Department, and the Health Physics Department.
The inspector interviewed several technicians regarding the adequacy of the training received.
The interviews revealed that the training had not included a review of health physics procedures and plant systems.
The inspector was particularly concerned that the new technicians were currently responsible for conducting a large portion of the routine program, but documentation was not available to indicate supervision had verified that the technicians had received adequate training on department procedures.
The licensee committed during the exit interview on July 24, 1981, that a program would be immediately initiated to ensure technicians received procedure training.
l This training is to be completed by August 14, 1981.
A written program had not been developed for retraining department personnel.
Records indicated that a few organized training sessions covering plant procedures were held during late 1980.
However, the re-training activities appeared to terminate with the onset of 1980-81 refueling outages.
Interviews and records indicated that formal re-training sessions had not been held during 1981.
The licensee stated that the Training and Counseling Department is in the process of developing formal initial training and retraining programs which include objectives, scepe, and a long range training schedule.
These programs are to be completed and implemented by late 1981.
This item is considered open and will be reviewed during future inspections.
No violations or deviations were identified.
7.
Engineering Controls The inspector reviewed the progress made to correct the airborne releases in the Unit I auxiliary building.
The licensee had initiated several Design Change Packages (DCP) to repair or modify the facilities. Most of the DCP's were either completed or nearing completion.
One DCP has t an estimated completion date of mid-1982 due to the inability to obtain a specific valve. Health Physics personnel stated that the work accomplished to date has apparently corrected a major portion of the previous problems. No significant relenes were observed thus far in 1981.
This item remains open pending completion of all DCP's.
No violations or deviations were identified.
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Job /Pos_ition _ Descriptions , l Job descriptions had not been completed which detailed the duties and responsibilities for the members of the Health Physics Department.
A job description for the Health Physics Superintendent had been comp 12ted.
However, similar Job descriptions had not been established for other positions. The licensee stated that they were in the process of writing the descriptions. September 1,1981, is the scheduled con.pletion date for all department job descriptions.
This item is considered open pending issuance of the job descriptions.
No violations or deviations were identified.
l 9.
Instrument Calibration I The inspector reviewed the QA/QC programs for various portable survey meters and the whole body counter. The following items were observed: a.
Beta Survey Meters The licensee uses an uranium slab to calibrate beta survey meters.
The vendor's literature listed the maximum surface radiation level from the slab as 190 mrad /h. However, beta radiation levels I associated with certain jobs (steam generator repair, valve maintenance, etc) may exceed 10 Rad /h, ANSI N323-1978, Radiation Protection Instrumentation Test and Calibration, Section 5.1, Calibration Standards, states, in part, "A calibration source or sources preferably should be of a radiation energy similar to that with which the instru- ! ment will be used and of a radiation exposure rate sufficient to reach full scale of any instrument to be calibrated." The licensee typically uses an Eberline R0-2A meter to establish beta radiation l evels. The R0-2A has a full scale range between 0-50 R/h. Since the maximum output from the uranium slab is only about 200 mrad /h, the beta survey meters had not been calibrated over the full range as recommended by ANSI-N323.
It was also noted that beta calibration data had not been recorded on the calibration sheet.
Procedure 1303.10 Revision 0, " Calibration for R0-2 and R0-2A, Survey Instruments," only required that gamma calibration data be recorded on the calibration form. The licensee stated during the exit interview on July 24, 1981, that they would investigate the possibility of obtaining a 90Sr
' calibration source in order to satisfy the recommendations of ANSI-N323 and revise the current calibration sheet.
No violations or deviations were identified.
b.
Neutron S_ur_vey_ Me_ters Eessentially the same concerns existed regarding neutron survey meters as discussed in Paragraph 9.a above. Procedure 1303.76, Revision 1, t " Calibration of PNR-4 Portable Neutron Rem Counter," requires an electronic (pulse generator) calibretion for the various meter ! l
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ranges.
The electronic calibration was supplemented with a neutron
response test usi~ng a 4.7 curie Pu-Be source which only provided j an approximate 30 mrem /h neutron field.
The PNR-4 survey meter has a 0-5 Rem /h range; therefore, the licensee program does not satisfy
i the recommendations of ANSI-N323, Section 5.1, regarding full scale source calibration and the use of a source with radiation energy similar to that with which the instrument will be used.
The licensee stated that the University of Arkansas has been contacted g negotiations are underway to obtain the use of the University's Cf neutron source to ensure that the recommendations of ANSI-N323 are satisfied.
This item is considered open.
f ' No violations or deviations were identified.
c.
Whole Body Counter i The licensee's whole body counting system had not Deen calibrated in ! order to meet the recommendations of ANSI N343-1978, "American National Standard for Internal Dosimetry for Mixed Fission and Activation i Products." Section 15.2 - System Performance Criteria of ANSI N343, ] states, in part, "Because of the importance of accuracy in in-vivo i determinations, an effort should be made to participate in an inter-
calibration program where several facilities can compare results using the same standard phantom with sources having calibrations traceable - to the National Bureau of Standards.
These measurements shall be made - for the ranges of organ burdens of interest - for example, 60-20,000
nanocuries of cobalt-60.
Section 15.3.3 - Quality Assurance, states, in part, "... In-vivo measurement instrumentation shall be calibrated prior to counting and shall be checked periodically during any
{ examination series to detect unusual conditions or malfunctions that i could give erroneous results." The licensee is in the process of
developing a calibration program for the whole body counter.
The j scheduled implementation date for this procedure is October 1, 1981.
No violations or des utions were identified.
10.
Response Tests For Survey Meters The licenst.e has not established response tests procedures to ensure that survey meters are properly tested prior to actual use.
ANSI N323-1978, i Section 4.6 - Periodic Performance Test, states, in part, "To assure proper operation of the instrument between calibrations, the instrument
shall be tested with a check source during operation and prior to each intermittent use.
Reference readings shold be obtained for one point , i on each scale D7 decade normally used." The licensee maintains a 10 microcurie Cs check source at the instrument stc. rage room to be ' used for response testing survey meters.
However, this source only j provided a maximum contact radiation level of about 2 mR/h.
In addition, ,
the inspector observed that instrument were usually issued without being ' response tested.
The licensee stated during the exit interview on
July 24, 1981, that a proper response test source would be obtained to ' ensure that the reconmendations of ANSI-N323 are satisfied.
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No violations or deviations were identified.
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11.
Evaluation of Contractor Personnel f The licensee had not established a procedure to provide direction and guidance for the evaluation of prospective contractor health physics
1 technicians.
The licensee stated that the basic guidance appearing in l ANSI-N 18.1-1971, " Selection and Training of Nuclear Power Plant Personnel" i is used as acceptance criteria.
The licensee acknowledged that ANSI-N18.1 is limited and does not provide specific, detailed guidance.
During the
exit interview on July 24, 1981, the licensee stated they would review ' . the need to establish a procedure to ensure that uniform guidance is
available for individuals within their organization assigned the responsi- > J bility of evaluating contractor personnel.
The proposed procedure would i include such items as requiring detail resumes of specific work assignments, ! duration of actual experience, guidance for accepting work experience,
etc.
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) No violations or deviations were identified.
l 12.
Audits i j The inspector reviewed audits of the Health Physics Department conducted i between October 1, 1980 - July 15, 1981.
Tne licensee had contracted j two outside consultants to perform special audits of health physics
activities during October and November,1980.
These audits contained } many of the findings that appeared in the Health Physics Appraisal report.
l The inspector also reviewed in-house QA/QC audits.
These audits were designed to determine compliance with existing procedures. The in-house ' team members did not include an individual with health physics experience.
These audits did not include evaluat%ns regarding such matters as the , j effectiveness of the Health Physics Cepartment, staffing, facilities, j training, or recommended changes to the existing Health Physics program.
The licensee stated that one of the responsibilities for the new Corporate '
Health Physicist would be to participate in the QA/QC audit programs.
. No violations or deviations were identified.
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Unresolved Items I - Unresolved items are matters about which more information is required in 'l j order to ascertain whether they are acceptable items, violations, or j deviations.
No unresolved items were identified during this inspectica.
1 14.
Exit Interview
At the conclusion of the inspection on July 24, 1981, the inspector met i i with those persons identified in Paragraph 1.
The inspection reviewed ! the scope of the inspection and the inspection findings.
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provided commitments for certain items discussed during the exit interview.
(See Paragraphs 5, 9, 10, and 11).
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