ML20128D793

Insp Repts 50-313/85-09 & 50-368/85-09 on 850415-19. Deviation Noted:On 850419,only Two Continuous Air Samplers Operable W/Necessary Characteristics to Satisfy FSAR Commitments

ML20128D793
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/21/1985
From:	Holley W, Martin L, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20128D739	List: ML20128D736 ML20128D755 ML20128D793
References
50-313-85-09, 50-313-85-9, 50-368-85-09, 50-368-85-9, NUDOCS 8505290204
Download: ML20128D793 (8)

See also: IR 05000313/1985009

Text

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC~ Inspection Report: 50-313/85-09 Licenses: DPR-51

50-368/85-09 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 (ANO), Units 1 and 2

-Inspection At: AN0 Site, Russellville, Arkansas

- Inspection Conducted: April 15-19, 1985

Inspector: 8 7

Ws'ld9' L. F olley, Radi,

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ion Specialist

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Facilities Radiolog al Protection Section

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Blaine iurray,' Chief

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acilities Radiological Dhte '

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' Areas-Ins'pected:  : Routine,. unannounced ' inspection of the licensee's radiation ,~ .J

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protection activitie~s.during the Unit 2 refueling outage including: -advanced-

planning and preparation;, staffing,U; training, and qualifications; ALARA;- _ _

external. exposure control; internal exposure control;' posting,' labeling, and.-

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worker. controls;, radioactive and contaminated material controls; surveys;

, - Jhealthi hysics!1ogs p and records; and' independent confirmatory surveys. An

? allegation regarding. improperly performed personnel 'monito' ring was also-

investigated. TheLinspection involved 44 inspector-hours _onsite by one NRC

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.Results: .Within the areas inspected, one deviation was identified (portable

P~ ' continuo'us" air monitors,' paragraph 9). The allegation could not be

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1r DETAILS

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1. ' Persons Contacted

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AP&L. '

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< 4 *J. M. Levine, ANO General Manager

I. D. Akins, Health Physics (HP) Supervisor

B. Baker, Operations Manager

4? *M. J. Bolants, HP Superintendent

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C. Burchard, HP' Supervisor

• P. Campbell, Plant Licensing Engineer

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• T. H. Cogburn, Special Projects Manager

E W. Hada, HP Supervisor

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I. D. Helm, HP Specialist (ALARA. Coordinator)

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a R. Green, HP Dosimetry Supervisor

• D.-B. Lomax, Plant Licensing Supervisor

g' , . *M. L. Pendergass, Engineering and Technical Support Manager

T. M. Rolniak, HP.. Trainer-2

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• J. D.' Vandergrift, Training Superintendent

D. Wagner, Assistant HP Superintendent

Others

• P. H. Harrell, NRC Resident. Inspector

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The NRC inspector also contacted other licensee employees, including HP

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-and administrative personnel.

• Denotes those present at the exit-interview.

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2. .- Open Item Identified During This Inspection -

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Open items are matters that require further review and evaluation by the-

inspectors or the licensee. ,Open items are used to document, track, and

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ensure adequate followup on matters of concern to the inspector.

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.0 pen Item Description Reference Paragraph

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313/8509-02; 368/8509-02 Portable HP Inst'rumentation 12

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, Radiation Response Check

" SAllegationFollowup

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I An' allegation was made to the' NRC on April 2,~1985, by a contractor

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employee concerning improper frisking upon exiting a radiological

controlled area l(RCA). Thel specific con _cern identified was that the HP

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monitor at the RCA control point allowed the licensee's HP personnel to

frisk improperly.

a. Observation: The NRC inspector observed, at various times on day and

night shifts, the practices of the HP monitors at the RCA control

point as well as the frisking procedures of licensee and contract

personnel. The NRC inspector observations determined that the

practices and procedures were adequate and that there was no

indication that selected personnel were allowed to violate frisking

procedures.

b. Personnel Interviews: .The NRC inspector interviewed the licensee

employees with respect to frisking procedures for personnel exiting

the RCA control point. Included in the interviews were eight HP

monitors who manned the RCA control point on various work shifts. It

was ascertained from the interviews that the licensee's HP personnel,

other licensee personnel-and contractors were not deficient in their

frisking procedures.

c. Conclusion

The NRC inspector did not substantiate the allegation that the

licensee's HP personnel were frisking improperly.

4. : Advanced Planning and Preparation

The NRC inspector determined that the licensee had made adequate plans in

advance of the refueling outage. The results of this planning and

preparation were evident by the availability of adequate supplies,

manpower, instrumentation, dosimetry, and ALARA activities.

No violations or deviations were identified.

5. Staffing

The NRC inspector reviewed the licensee's functional organization

regarding the radiation protection program to determine compliance with

~ the Final Safety Analysis Reports (FSARs),- Sections 12 and 13 and

Technical Specifications (TS), Section 6.2.

The HP staffing appeared sufficient to support the refueling outage. The

licensee had hired 54 contract HP technicians to supplement the permanent

plant staff. 'The licensee was utilizing one HP supervisor per shift as a

roving HP observing the tasks being performed for the outage. Radiation

' work permits (RWPs) were reviewed and approved by AND ANSI-N18.1-1971

qualified personnel,

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, ' permanent HP dosimetry, supervisor and the addition of a'HP specialist.

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6.- 1 Training'and Qualifications ,,

TheNRCinspectorreviewed'thetrainingandqualificat'i$nsofHP. contract

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personnel related to the' refueling outage activities to determine -

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conformance to the FSAR, Sections 13.1 and 13.'2 commitments and-

S-  ; requirements.of TS, Section 6.4'and'10 CFR 19.12.

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The NRC inspector performed a review of the qualifications of the contract ,

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HP, technicians.. This review included evaluation criteria used by the

s ' licensee to' establish ANSI-N18.1-1971 qualification for contractor HP

technicians! ;The NRC' inspector also reviewed the licensee's screening,.

, - ttraining,'and. examination program for contractor personnel.

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No violations ~ or deviations were identified. *

( ,7. ALARA

, The~1icensee's refueling outage ALARA program was reviewed to determine

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compliance.with the requirements.of 10 CFR Part 20.1 and the

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recommendations of Regulatory Guides (RGs) 8.8 and 8.10.-

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e 'i .Th'e NRC: inspector determined that the licensee had set a goal not to

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exceed 233 man-rem for this refueling outage (2R4). . At the time of this ,

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inspection,199 man-rem had been expended. The: outage skin contamination- .

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incidents-had occurred t as

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this inspection. licensee is investigating. skin l (~

pML'3 incidentsiand taking positive corrective actions'(counseling and */

f^- (.. ; : retraining),to reduce skin contamination incidents. ALARA personnel are i

F , 3 actively; involved in planning and scheduling of maintenance activities - '

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!during the outage. Outage tasks received an initial evaluation and jobs 7

• J s + w (which are estimated.to require the expenditure of greater than 1 man-rem .

w i .; require-a: separate ALARA review. The licensee tracks both man-rem and: '

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.- .' man-hours expended on each task on a daily basis by implementing'the .

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.,  :!'ALARA' Data: Bank" computer program.

O 'iRWPl data; -Each outage task is assigned a man-rem goal. The major tasks >

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R. * are reviewed for dose reduction by the ALARA committee. The NRC' inspector.

. i i h y $ ;were not performed because the ALARA coordinator -

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8. External Exposure Control'

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'The NRC inspector reviewed the licensee's external exposure' program to

determine compliance with 10 CFR 20.101, 20.102, 20.202,-20.401 and 20.403

and commitments of the FSAR, Section 12.3.2.

'The NRC inspector determined that each person entering the RCA was

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routinely issued a thermoluminescent dosimeter (TLD) and self reading

' dosimeter (SRD). Additional dosimetric devices, such as high range SRDs

or extremity TLDs, were issued when required in certain areas such as high

radiation areas, steam generator work, or as specified on an RWP. The NRC

inspector reviewed a selected sampling of the RWPs issued during the . '

< refueling outage. The RWPs incorporated sufficient radiological controlsL ,

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'The.NRC inspector reviewed NRC Form-4 and NRC Form-5 information for the

. permanent plant staff, contractors, and visitors. The information '

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' required by the forms was current and complete. The licensee had ,

, established a program to provide a daily listing of current worker .

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y ,7_ exposures based-on SRD results. The listings were posted for review by . ,

, , the workers. The' licensee' maintains an in-house TLD system which allows

, for immediate processing of TLDs to verify SRD results. An administrative

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limit procedure had been established to track workers with high exposures

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, or the potential for high exposures.

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No v'iolations or deviations were identified.

' 9. Internal Exposure Control

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The NRC inspector reviewed the licensee's internal exposure program to

.- determine compliance with the requirements of 10 CFR 10.103 and i

commitments in Sections 12.3 and 12.4 of the FSAR.

The NRC inspector did not identify any problems regarding the respiratory _

protection program. The NRC inspector noted that the licensee routinely-

performs whole body counting on individuals prior to entry into an RCA and

upon completion of the work assignment at the site. The NRC inspector

reviewed the maximum permissible concentration (MPC) hours record in the

MPC-hour log.

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The NRC inspector reviewed the' licensee's continuous air monitoring (CAM)

program for gaseous, particulate, and iodine airborne concentrations. The

NRC inspector noted that about 13 out of 15 CAMS were out-of-service. The

two operable CAMS were dedicated to the Technical Support Center and a

separate radwaste storage building. As such, a continuous air monitoring

program was not in place for work activities in the power block areas.

~The' licensee stated that the vendor that had supplied their original CAMS

had gone out of. business and they had been unable to obtain replacement

parts.

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The Unit 1 FSAR,'Section 11.3.2.3 and the Unit 2 FSAR, Section 12.4.2.3

states that for each unit, " portable air monitors consist of four air

samplers that~are capable of continuously monitoring and recording

particulate and gaseous activity. In addition, these monitors can be

equipped with an iodine collection cartridge that can be counted in the

laboratory." The failure to maintain instrumentation capable of

implementing a continuous air monitoring ~ program is considered a deviation

of FSAR commitments. (313/8509-01; 368/8509-01)

' No violations were identified.

10. Posting,- Labeling, and Worker Controls

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The NRC inspector examined posting, labeling, and control for radiation

areas, high radiation areas, and contaminated areas against-requirements

of 10 CFR Parts 20.203, 20.204, and 20.207 and station procedures

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developed in accordance with TS 6.11 and 6.13.

The NRC inspector performed several inspections of the facility, including

the RCA, and observed the RCA and Unit 2 access control, contamination

control, and exit radiation monitoring controls. All areas observed

appeared adequately posted, labeled, and properly controlled.

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No violations or deviations were identified.

11. Radioactive and Contaminated Material Controls

The NRC inspector examined the radioactive material labeling and

identification against the requirements of 10 CFR Part 20.203. The NRC

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inspector observed the licensee's control of contaminated tools and

equipment during the refueling outage. Within the RCA, several areas were

dedicated to storage of radioactive tools,' equipment, and components.

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Containers were marked.with labels that identified the radioactive

!- contents.

No violations or deviations were identified.

12. Survey Program

The NRC inspector reviewed portions of the licensee's survey program to

determine compliance with 10 CFR Parts 20.201 and 20.401.

The NRC inspector observed the use of portal monitors and personnel

ifriskers by various personnel. The NRC inspector reviewed a sampling of'

the survey records compiled for the refueling outage. These records

included radioactive airborne surveys, radiation surveys, and

. contamination surveys. These survey data appeared to be adequate,

disseminated in a timely manner, and were used in work planning and deso

control.

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The NRC inspector noted that the licensee's prior-to-use response test

procedure for portable survey meters did not include full-range radiation

test levels. The licensee's response test procedure involved the use of

small sealed sources which only provided radiation levels at about

10 mR/hr. However, a survey instrument might be used to measure actual

radiation levels of several hundred mR/hr. This concern was discussed

with the licensee during the exit interview on April 19, 1985. The -

licensee stated that their present response test program would be reviewed

to ensure that survey meters are response tested, prior to use, for the

radiation level expected to be measured. The license stated that the

review and any necessary procedure changes would be completed by

October 1, 1985. This is considered an open item pending review of the

NRC inspector's concerns by the licensee. (313/8509-02; 368/8509-02)

No violations or deviations were identified.

13. Health Physics Loos and Records

-The NRC inspector examined various records to determine compliance with

10 CFR Part 20.401 and the requirements of TS, Section 6.10 and FSAR,

Section 13.6.

The NRC inspector reviewed selected entries of the HP log for the

refueling outage, TLD/SRD discrepancy reports, and radiological incidents.

No violations or deviations were identified.

14. Independent Confirmatory Surveys

The NRC inspectors made confirmatory radiation surveys to verify the

licensee's survey results.3

During inspections of the ANO, Unit 2 containment and auxiliary buildings,

the NRC inspector made independent measurements and determined that the

designated areas in the' radiation control area were properly posted and

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controlled.

No violations or deviations were identified.

15. Exit Interview

The NRC inspectors met with licensee representative's and the NRC resident

inspector identified in paragraph 1 at the conclusion of the inspection on

April 19, 1985. The NRC inspectors summarized the scope and findings of

the inspection presented in this report. The licensee stated that the NRC

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inspector's concern regarding the survey meter response tests and the FSAR

commitments for CAMS would be reviewed.

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