IR 05000368/1986017
| ML20215D394 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/05/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8612160348 | |
| Download: ML20215D394 (2) | |
Text
September 30, 1986
SUBJECT:
Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Report 50-368/86-17
Dear Mr. Gagliardo:
The subject report has been reviewed.
Responses to the Notice of Violation and Notice of Deviation are attached.
Very truly yours, i
a bl gw J. Ted nos, Manager NucTear Engineering and Licensing ll JTE/RJS/sg (/
Attachment
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f(Zl(7[b tyV MEMBER MICOLE SOUTH UTILITIES SYSTEM
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NOTICE OF VIOLATION During an NRC inspection conducted on June 23-27, 1986, a violation of NRC requirements was identified.
The violation involved the failure to follow procedures.
The violation and response are listed below.
Failure to Follow Procedures ANO Unit 2 Technical Specification 6.11 requires that " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving persennel radiation exposure."
AN0 Procedure 1612.003 requires, in part, that " personnel designated to perform tasks controlled by an RWP are responsible for:... reviewing the RWP radiological information... special instructions... complying with instructions and requirements specified on the RWP..." Radiation Work Permit (RWP) No. 860193 was issued for work involving the Wyle Laboratory Test Trailer.
AN0 Procedure 1622.008 requires, in part, that " radioactive material stored outside of the controlled access area be accounted for in accordance with the tagging and accountability instruction of the procedure."
Contrary to the above, the NRC inspector determined on June 26,1986, that:
1.
On June 26, 1986, workers did not follow RWP requirements for the handling of radioactive material removed from the reactor containment in accordance with RWP No. 860193.
2.
Accountability of radioactive material temporarily stored outside of radiation controlled areas (in the Wyle Laboratory Test Trailer) was not in accordance with Procedure 1622.006.
This is a Severity Level IV violation.
(Supplement I) (368/8617-01)
Response The contractor Health Physics technician assigned to provide Health Physics support for removal of radioactive material from the reactor building was not informed nor aware that a specific radiation work permit governed the removal of the material.
As a result, the technician signed in on a general radiation work permit.
This permit did not contain the specific requirements of the appropriate radiation work permit; however, the technician escorted the radioactive material to the test trailer using good Health Physics controls and practices.
No personnel exposure or spread of contamination resulted from the activity.
Subsequent to the identification
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of the. violation by'the NRCLInspector, the Health Physics supervisors and technicians, including _ contractor. technicians, were advised of their responsibility to ensure work.'is performed to the correct radiation work permit and that they understand and ensure compliance with the requirements of the correct radiation work permit.
Contrary to the requirements of Procedure.1622.008, " Marking and Handling of Radioactive Material and Equipment", the equipment sto' red at the Wyle trailer was not tagged or accounted for on the Temporary Radiological Materials Storage Area Log.. Subsequent to the identification of this violation, all temporary radiological material storage areas outside the controlled area were reviewed for compliance with 1622.008.
The specific instance cited was brought into compliance.
Health Physics supervisors and technicians were advised of their responsibilities with regard to storage and tagging requirements and procedural compliance.
For each instance cited, plant procedures provid'ed adequate guidance which, if followed, would have been appropriate for the activities involved. AP&L provides employees and contractors training on procedure compliance and responsibilities.
The counselling sessions reminded them of the need for increased attention to detail and adhe'rence to procedures.
Disregard or
' repetitive incidents of failure to comply with procedural requirements will result in disciplinary actions.
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NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on June 23-27, 1986, a deviation of a commitment to the NRC was identified.
The deviation involved the failure to implement commitments made to the NRC concerning access control.to the fuel element transfer tube.
The violation and response are listed below.
-Fuel Transfer Tube Access Control NRC Inspection and Enforcement Bulletin 78-08 required, in part, that licensees inspect reactor plant fuel element transfer tube areas for shielding and accessibility.
The licensees were to implement certain posting and access controls over areas that could provide possible personnel access.
The licensee responded to the NRC in accordance with the Bulletin's instruction on August 14, 1978, stating, in part, that "We have identified an area in which a section of exposed fuel transfer tube is located in both ANO 1 and 2..... Per the subject bulletin, we will post and assure positive control of access to entryways into this area."
In deviation from the above, the NRC inspector determined on June 26, 1986, that the licensee had not posted or implemented positive access controls to the Unit-2 fuel element transfer tube.
(368/8617-02)
Response In attempting to reconstruct the actions taken by AP&L to address the bulletin, it appears that there were intentions to post the areas, as stated in our response, each refueling.
It is probable that during the first refueling outages following the bulletin, the areas were posted with temporary signs.
However, it does not appear that these actions were repeated in future outages.
Subsequent to the identification of the deviation, AP&L provided positive access controls for the Unit 2 area.
For each of ten gratings which provide access to the fuel transfer tube area, carbon steel plates were fabricated and red plastic signs were attached which specified that Health Physics Superintendent or Shift Supervisor authorization for removal of grating is required.
These metal plates were welded to the grating sections.
Additionally, a small plate was welded over each grating clip to prevent unintentional removal for access to the area.
The same controls will be added to Unit 1 during the refueling outage beginning in September, 1986.
AP&L's original method of addressing IE Bulletin 78-08 was inadequate considering the fact that it required the administrative posting of the fuel transfer area each refueling.
The permanent signs affixed to the subject areas in Unit 2 and to be affixed to the affected areas in Unit 1 will assure future compliance without the risk of administrative breakdown.
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