IR 05000313/1986031

Insp Repts 50-313/86-31 & 50-368/86-31 on 861006-10. Violation Noted:Failure to Provide Timely Internal Radiation Exposure Assessment

ML20211M165
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/04/1986
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211M148	List: IR 05000313/1986031 ML20211M145 ML20211M158
References
50-313-86-31, 50-368-86-31, IEB-78-07, IEB-78-08, IEB-78-7, IEB-78-8, NUDOCS 8612160285
Download: ML20211M165 (11)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

'NRC Inspection Report: 50-313/86-31 Unit 1 Licenses: DPR-51 50-368/86-31 Unit 2 NPF-6 Dockets: 50-313 50-368 Licensee: Arkansas Power and Light Company (AP&L)

P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One (AN0)

Inspection At: Unit-1, AN0 Site, Russellville, Pope County, Arkansas Inspection Conducted: October 6-10, 1986

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Inspector: -

12-!4b H. Chahey,ladiation Specialist, Facilities Date Radiological Protection Sections Approved: d[WM lYkM B.Murray, Chief,FpilitiesRadiological Date Protection Sections Inspection Summary Inspection Conducted October 6-10 1986 (Report 50-313/86-31; 50-368/86-31)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program for the refueling outage (1R7) of Unit 1. The NRC inspector also reviewed the licensee's response to NRC Inspection and Enforcement (IE)

Bulletins 78-07 and 78-0 Results: Within the areas inspected, one violation was identified (failure to provide timely internal radiation exposure assessment, paragraph 8), and no deviations were identifie g 2 g 2g g ag g 3 G

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DETAILS Persons Contacted ,

AP&L

• J. M. Levine, Director of Site Nuclear Operations

• T. C. Baker, Technical Support Manager

• D. R. Howard, Special Projects Manager

• D. B. Lomax, Plant Licensing Supervisor

• P. E. Campbell, Plant Licensing Engineer

• E. E. Bickel, Health Physics (HP) Superintendent

• R.. Lane, Engineering Manager

• D. J. Wagner, Quality Assurance Auditor

• 0. Cypret, AP&L Corporate HP Specialist D. G. Horton, QA Superintendent B. L. Bata, QA Auditor R. E.. Green, HP Dosimetry Supervisor L. E. Qualls, Dosimetry Technician J. S. Fancher, HP Technician T. R. Smith, HP Supervisor B. C. Burchard, HP Supervisor

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D. W. Akins, Radwate Supervisor I. Mosquito, Unit-1, Outage Coordinator W. L. Hada, HP Supervisor D. L. Helm, HP Specialist (ALARA Coordinator)

J. Waid, Supervisor, Technical Specialist Training M. R. McIntosh, HP Supervisor T. Rolniak, Lead Trainer HP and Radwaste J. Deal, Trainer HP and Radwaste R. Deal, Dosimetry Technician Others

• D. Johnson, Senior NRC Resident Inspector R. Drake, Applied Technology of Barnwell Inc., HP Supervisor G. Conley, ATBI HP Technician A. Murray, ATBI HP Technician

• Denotes those present at the exit interview on October 10, 198 The NRC inspector also interviewed other licensee employees including reactor operators and contracted HP personne . Licensee Actions on Previous Inspection Findings (Closed) NRC IE Bulletin 78-07: Protection Factors For Air-Line Respirators and Supplied Air Hoods - The licensee's July 24, 1978, response to this Bulletin is considered adequat Currently, the licensee

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does.not utilize supplied air hoods. P_rotection factors used by the licensee for the air-line respirators agree with the current Appendix A of 10 CFR Part 20 requirements. This item is considered close (Closed) NRC IE Bulletin 78-08: Radiation Levels from Fuel Transfer Tubes _- The spent fuel element transfer tubes in both Units 1 and 2 were inspected and found to provide positive control regarding personnel access. This item is considered' close (Closed) Deviation (368/8617-02): Fuel Transfer Tube Access Control - The NRC inspector end the ANO senior _ resident inspector verified that accessible areas around Unit 1 and 2's spent fuel element transfer tubes had warnings posted and positive physical. controls to prevent an inadvertent entry into the areas during spent fuel transfer operation This item is cor.sidered close (Closed) Violation (368/8617-01): Failure to Follow Procedures- During this inspection, radiation work permit and material tagging requirement adherence were verified to be satisfactory for materials being handled outside of radiologically controlled areas. This item is considered close (Closed) Violation (313 and 368/8616-01): Failure to Implement Curren Procedures - The licensee was noted to have provided controlled copies of the operating procedures for the operation of the personnel dosimetry system, and that current procedures / forms were being utilized by operating personnel. This item is considered close (Closed) Open' Item (313-368/8419-02): HP Superintendent Review of Training Department Lesson Plans / Procedures - The licensee's current lesson plans involving radiological protection training activities were verified to_have been reviewed by the HP Superintendent. This item is considered close (Closed) Open Item.(313/8214-17 and 368/8211-17): NUREG-0737 Item III.D.3.4, Control Room Habitability - This item has been resolved in correspondence between AP&L and the NRC (NRC Letter 02821135, from R. A. Clark, to W. Cavanaugh AP&L, dated February 12, 1982). This item is-considered close :(Closed) Open Item (368/8122-03): Portable Beta Dose Rate Measurement Instrument Calibration - The licensee had performed a comprehensive evaluation of their beta calibration standard which resolved the concerns in this area. This item is considered close . Inspector Observations The following is an observation the NRC inspector discussed with the licensee during the exit meeting on October 10, 1986. This observation is

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neither a violation nor an unresolved item. This item was recommended for licensee consideration for program improvement, but it has no' specific

, regulatory requiremen Air Sampling - The licensee's air sampling program does not provide adequate information concerning plant air flow characteristics and location of airborne sources. (See paragraph 8 for details)

4. Advance Planning and Preparations The NRC inspector reviewed the licensee's preparations for the Unit 1 refueling outage (IR7). The NRC inspector was specifically interested in jobs that involved radiation protection activities such as auxiliary building and reactor containment decontamination, insulation removal, primary side steam ger.erator inspection, secondary side steam generator sludge removal and inspections, incore detector removal and disposal, and reactor coolant pump (RCP) removal and inspection. The NRC inspector held discussions with outage coordinators and HP personnel working as liaisons in the AN0 Planning and Scheduling Section of the Work Control Center. The NRC inspector attended daily scheduling meetings where upcoming events and current problems were discussed; all departments associated with the outage were well represente No violations or deviations were identifie . Staffing, Qualifications, and Training The licensee's staffing, qualification, and training programs were inspected for compliance with the requirements of Unit 1 TS 6.3 and 6.4; and the recommendations of NRC Regulatory Guide (RG) 1.8 and industry standard ANSI N18.1-197 The NRC inspector noted that a new Superintendent of the Health Physics Section had been appointed effective August 14, 1986, to replace the acting HP Superintendent (Assistant HP Superintendent), and that the position of Assistant HP Superintendent had been eliminated from the ANO i organization. The new HP Superintendent's (formally a staff HP)

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qualifications were reviewed and found to satisfy the Unit 1 and 2 TS and NRC RG 1.8 recommendations. The new HP Superintendent is certified by the American Board of Health Physic The licensee had resolved the concern regarding the lack of HP expertise for QA personnel that perform audits of radi cion protection activitie This concern was discussed as an observation in NRC Inspection Report 50-313 and 368/86-1 The NRC inspector determined that the licensee had hired approximately 60 temporary contract health physics technicians for the 1R7 outag Approximately 36 of these technicians satisfied the ANSI N18.1-1971 criteria for senior HP technician The NRC inspector reviewed selected l

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temporary employee resume Assignment of personnel appeared to be consistent with their individual qualification Personal resumes of personnel hired for positions in the HP group had been individually reviewed by HP supervisors and personnel were tested and trained per AN0 procedures prior to work assignment in the HP group. Training programs for other contract workers (maintenance, operations, and technical specialities) conformed to the requirements of 10 CFR Part 19.12 and ANSI N18.1-1971. Screening test, lesson plans, and classroom training of contractor technicians were reviewed by the NRC inspector. The NRC inspector noted that the licensee had provided certain ANO HP technicians with specialized training in industrial atmosphere sampling (confined space breathing atmospheres). This action resolves the concern, addressed in NRC Inspection Report 50-313/86-10, regarding HP technicians performing industrial safety breathing air monitoring without specialized training in regulations and equipment us No violations or deviations were identifie . ALARA The NRC inspector inspected the licensee's ALARA program to determine agreement with the recommendations of NRC RGs 8.8 and 8.10 and adherence to AN0 procedures and directive The licensee had established radiation exposure, personnel contamination incident, and radioactive waste goals for the IR7 outage that support the overall annual goals for plant operation. The NRC inspector noted that the licensee's performance was less than projected for the current status of the outage and that goals for cumulative personnel exposure and personnel contamination incidents may be exceeded by the end of the outage. The licensee's preplanning and use of shielding and decontamination to reduce both external and internal exposures was reviewe No violations or deviations were identifie . External Radiation Exposure Control The licensee's external radiation exposure control program was inspected to determine agreement with the commitments contained in the Section 12 of the Unit 1 Updated Safety Analysis Report; the requirements of Unit 1 TS 6.11 and 6.13, 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409; and the recommendations of NRC IE Information Notices 86-22, 86-24, and 86-44, NRC RGs 8.2, 8.4, 8.7, 8.8, 8.13, 8.14, and 8.28, and industry standards ANSI N13.11-1983, N13.5-1972, and N13.27-198 The NRC inspector inspected personnel exposure-records, authorizations to exceed ANO administrative exposure limits, access controls over high radiation areas, dose rate evaluations of RCP components and steam generator areas, special dosimetry processing, records on the use and

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placement of multiple whole' body and extremity dosimetry, observed

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wearing /use of multiple yhole body and extremity TLDs, skin exposure

. evaluations, lost dosimetry. evaluations, and pers'onnel exposure trackin The NRC inspector discussed with the licensee the use of.the new

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thermoluminescence dosimetry (TLD) syste The licensee' sinew TLD system '

for monitoring personnel exposures to beta, gamma, and neutron radiations is a state-of-the-art 4. element.TLD badge. 'The _ licensee's evaluation of exposure to personnel not wearing ~ eye protection was reviewed and fo'und to _- i satisfy.the requirements of 10 CFR Part 20.401'and Form NRC-5. The NRC ,

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inspector ~ verified exposura controls for-high radiation and very high I radiation areas in the plan #

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- No violations or deviations were identifie ~

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i Internal Radiation Exposure Controls ~

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The licensee's program for control of. internal exposures..was inspected to %L j determine compliance with the requirements of 10 CFR Paht 20.103 and the

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! recommendations of RG 8.'15 and NUREG-004 :

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The NRC inspector reviewed respiratory protection equip' ment (RPE)

concerning maintenance, issue, testing, return, and facilities for the ,

decontamination and sanitizing of RPE. The NRC inspector noted potential problems with the licensee's air sampling program during inspections of f f

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work areas on the turbine deck and the spent fuel pool deck. Two continuous 4 air monitors (CAMS) were observed using plastic tubing to draw samplest

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from the high velocity air streams coming from unfiltered portablei j ventilation systems providing. ventilation to two radiological work areas.

- Both of these CAMS were associated with work on the' Unit 1 steam' system

components. The problems concerning the use of CAMS to s' ample"such air streams were discussed, and that if isokinetic. sampling could not be

employed with the CAMS, general area continuous air samplers would provide more reliable information. Methods to improve the CAM program were M l discussed. The licensee stated that more supervisory attention of the CAM ~

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i The NRC inspector also noted, after observing work in an open, top tent on the spent fuel pool deck'with workers wearing air-line respirators, and

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I i discussions with the technician in charge of work activities, that general (L area airborne radioactivity grab samples of the work area did not

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adequately take into consideration sampler location relative to ventilation

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flow paths and the-potential; source of radioactivity. The NRC inspector determined that the licensee very rarely performs smoke testing of air flow currents when establishing airborne radioactivity sampling locations. The licensee' stated that the CAM and grab air.. sampling programs would be

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The NRC inspector noted that the licensee had established an airborne ,

_ exposure tracking program-for personnel working in various portions of the l~ plant. 10 CFR Part 20.103.a(3) requires, in part, that "for the purposes a

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/,l G 4 Mofndetehningcompliancewithkherequirementsofthissection'the licensea sh671 use suitable meas;1rements 'of concentratiers of radioactive i

materials ia air.Nfor detecting:and evaluating airborne radioactive 7 "(,, 9aterials in restricted areas and in addition . . . shall use measurements

' of radioactivity in the body measurements . . . for the timely detection and assesment of individuals intakes of radioactivity by; expos,edo e

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individuals." ANO Unit 1 TS 6.10, requires,11 ggavt, ,that "procedurh for:

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I persor.r.eltradiation protection shall be pr.epared" consistent with the requirennts 6f 10 CFR Part 29 and shall be . . . adhered to for all ,.

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seperations involving personnel radiation exposure." Licensee i m -proceduNs 1622.015, " Bioassay Sampling Program," and.1609.010, "MPC-hour

,nt and 4taytime Calculations," require that personnel be given a whole body

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" countdi/BC) (direct bioassay) when they exceed 2 MPC-hours of airborne

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ci radioactivity during.any day ors 10 MPC-hours exposure during any 7-day

' periad. During several revicws of MPC-br tracking records for ANO

,y e- workers, the NRC inspector determined that the licenseelcould not determine in a timely manner whether any worker had been exposed to

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airborne radioactive materials above or below the limits of 10 CFR Part 20.103. Licensee 19C-or tracking records were found to be on an naverage of 25 days old. : As 'of October ~9,1986, the licensee was processing

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for 4ausessment air sampler collected on September 15, 1986. The NRC

. inspector further determined that at least two persons with possible MPC-hr uptakes ranging from greater than 2 MPC-br in one day to 25 MPC-hr in one day had not teen scheduled for a WBC until the NRC inipector noted it to the licensee $n October 6, 1986. Thine specific purported exposures les collected on were Septemberbased 12, on 1986.general The area failureand breathing to provide timelyzone air samp'essment of personne ass

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exposures to airborne radioactive materials is an apparent violation of the 110 CFR Part 20.103.a(3). (313/8531-01) , ,

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Deficiencies in the licensee's MPC-hr tracking and bioassa[ program have laiso been addressed previously in paragraph 4.a of NRC Insipection -

'f;eport 50-313/86-16, and paragraph 7.c of 50-313/82-36 which invohed a s similar violati6 .

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i No deviations were identified.

. Posting, Labeling, and Worker Controls The licensee's program for control;rf workers, posting of the areas, and labeling of radioactive materials wa,s inspected for cospliance with the requirements of Unit 1 TS 6.11 and 6.12, and 10 CFR Parts 19.12, 20.203, 20.205, 20.207, ar.d ?0.301. The NRC inspector also reviewed the licensee's

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. actions taken in regard to NRC IE Bulletin 78-08, " Radiation Levels from fuel Element Transfer Tube's."

i The NRC inspactor reviewed the licensee's posting of radiation areas, high

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l radiation areas, the' positive access controls establishea over very high

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l radiation areas within the reactor containment and auxiliary building, 2 airborne radioactivity a'reas, packaged waste, and radioactive material storage area The NRC, inspector noted that the HP technicians manning i the control point within Unit l's containment did have ready access to he i RWPs applicable to each work are The NRC inspector noted that the licensee's RWPs had type written instructions thus resolving the concern raised in NRC Inspection Report 50-313/86-16 regarding legibility of RWP instructions. Also, the NRC inspector reviewed the compliance with radiological control instructions involving several RWPs and the tagging i of radioactive materials located outside of controlled area I The NRC inspector reviewed the control and posting of the Unit 1 fuel element transfer tube. The NRC senior resident inspector verified the same for Unit 2. Licensee actions to post and control access to the aforementioned areas satisfied the requirements of NRC IE' Bulletin 78-0 No violations or deviations Cere identifie . Control of Radioactive Materials (RAM) and Contamination and Radiological Monitoring The licensee's programs for the control and survey of RAM were reviewed for compliance with the requirements of Unit 1 TS 6.11 and 6.13, 10 CFR Parts 19.12, 20.4, 20.5, 20.201, 20.203, 20.205, 20.207, 20.301, 20.401, and 20.40 The NRC inspector inspected the licensee's radiological survey program involving work areas, stor age' areas, change rooms, lunch and meeting rooms, contractor service facilities, and radiological control points for the surveying and release of materials and personnel. The NRC inspector also reviewea the control exercised over radioactive materials transferred to onsite vendor facilities for testing and maintenance. sTemporary work areas established outside of the reactor auxiliary buildings and containments were inspected. Logs of material removed from radiologically controlled areas were reviewed for completenes The NRC inspector performed confirmatory measurements of radiation dose rate levels within and outsida of the licensee's radiologically controlled facilitie All readings obtained agreed with documented surveys performed by the license The NRC inspector inspected controls and work operations involving reactor vessel head work, incore detector removal and disposal, RCP inspection, general decontamination, and reactor refueling activities. The licensee's radiological controls for maintenance on the Unit 1 steam supply system and l turbine generator components were inspected. The licensee's controls appear to effectively control personnel exposure to the radioactivity and control the material removed from the system for maintenanc \

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9-l The NRC inspector inspected the low-level Radioactive Waste Storage j

.. Building and noted that the licensee had resolved the concern addressed in i

.NRC Inspection Report 50-313/86-16, regarding the location of the l building's radioactive liquid sump diverting manifold valves and the storm '

drain nearby. The licensee had relocated valves, capped open drain lines, built a coffer dam in front of the diverting manifold, and provided an emergency watertight cover for the storm drai No violations or deviations were identifie . ' Exit Interview The NRC inspector met with the licensee's representatives identified in paragraph 1 of this report at the conclusion of the inspection on October 10, 198 The NRC inspector summarized the scope and the results of the inspectio '

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ATTACHMENT TO NRC INSPECTION REPORT 50-313/86-31 APPENDIX B DOCUMENTS REVIEWED'

TITLE REVISION , DATE AP&L and AND Crganization Charts O 09-15-86 Radiolooical Respiratory Protection Procedures 1609.001, Issue and Return of Respiratory Protection Equipment 5 08-26-86 1609.006, Use of Dial Air Regulator /MSA Manifold for Distribution of Breathing Air 1 12-12-85 1609.012, Respiratory Protection Program Evaluation 1 06-20-86 General Radiolooical Work Procedures 1622.001, Radiological Surveys and Documentation 5 09-26-86 1622.003, Radiological Posting and Entry Requirements 7 05-07-86 1622.006, Radiological Air Sampling Program 6 08-27-86 1622.007, ALARA Job Coverage Practices 4 05-29-86 1622.013, High Radiation Area Doors 6 06-20-86 1622.016, Assignment of Skin Dose From Contamination 2 08-27-86 1622.017, Operation of a Control Point 1 04-22-85 1642.002, Periodic Test Requirements for the UD-710A Automatic TLD Reader O 06-20-86 Other Procedures 1053.005, Confined Space Entry Program O 06-20-86 Training Lesson Plans:

AH-40100-OOO, Contract HP Technician Test O 05-29-86

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AH-40201-OO1, ANO Site Orientation O 05-30-86 AH-40202-OO1, Procedure Requirements and Responsibilities O 06-04-86 AH-10010-OO3, Confined Space O Radiation Work Permits:

G61302. Removal of Reactor Coolait Pump A and

Transfer to Spent 'ruel Area O 09-24-86

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G6143G, Reactor Coolant Pumo A Assembly Inspection and Overhaul 3 09-28-86

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TITLE REVISION DATE 861439, Inspection and Overhaul of Reactor _ ,

Coolant Pump A Casing O 09-29-86 861190, Wyle MOVAT Test Trailer Work O 861179, Enter and Inspect U1 Moisture Sepa , Control Rod Drive Work O 10-7-86 Memorandum AP&L No. NP-86-0193:

Subject: Evaluation of AND Beta Calibration -

Source 06-27-86 Memorandum AP&L No. OLC-014-08:

Subject: PSC Action Tracking-Item C554, NRC Open Item - Control Room Habitability 01-10-84 Le t t e* - NRC No. 02821135:

Gubject: SER for Unit 1 and 2 Control Room Habitability 02-12-82 Training Records for:

Anderson, C., Fowler, S., Moore, D., Cooper, G., Laureigh, L.,

Mitchell, F., Celletti, M., Perkins, L.,

Radiation Exposure Records for:

Edwards, G., Anderson, O., Mealy, Massengale, Jaminson, Moody, Patterson, Mosquito. I., Blanscet, R., Teeter, Tate, Holman l

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