ML20151N871
| ML20151N871 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/08/1988 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151N827 | List: |
| References | |
| 50-313-88-02, 50-313-88-2, 50-368-88-02, 50-368-88-2, NUDOCS 8804260031 | |
| Download: ML20151N871 (8) | |
See also: IR 05000313/1988002
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APPENDlX 8
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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-NRC Inspection Report:
50-313/88-02
Operating Licenses:
OPR-51
50-368/88-02
Dockets:
50-313
50-368
Licensee:
Arkansas Power & Light Company (AP&L)
P.O. Box 551
Little Rock, Arkansas 72203
Facility Name:
Arkansas Nuclear One (AN0)
Inspection At:
AND Site, Russellville, Pope County, Arkansas
Inspection Conducted:
February 21-26, 1988
Inspector:
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H. D. Chdnby,'Radiatiori Specialist, facilities
.Date ~
Radiological Protect'on Section.
Approved:
Ok 0,
llAL.4/A
8
B. Murray, ClieT,~ Facipities Radiological
Oate/
Protection Section
Inspection Summary
Inspection Conducted February 21-26, 1988 (Report 50-3: l/88-02; 50-368/88-02)
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Areas Inspected:
Routine, unannounced inspection of the licensee's radiation
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protection activities during the Unit 2 refueling outage (2R6).
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Results:
Within the areas inspected, one violation (failure to sur' rey and
post, paragraph 5.e) was identified.
No deviations were identified,
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DETAILS
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Persons Contacted
- D. Akins, Radioactive Waste (Radwaste) Supervisor
- T. Baker, Technical Support Manager
- E.' Bickel, Health Physics (HP) Superintendent
- E. Ewing, Assistant Plant Manager
- 0. Lomax, Plant Licensing Supervisor
- P. Michalk, Plant. Licensing Engineer
- S. Quennoz, Plant General Manager
- R. Wewers, Work Control Center Supervisor
-Others
- W. Johnson, Senior NRC Resident Inspector
- Denotes those present at the exit interview on February 26, 1988.
2.
Inspector Observations
The following are observations the NRC inspector discussed with the
licensee during the exit interview on February.26, 1988.
These
. observations are not violations, deviations, unresolved items, or open
items. These observations were identified for licensee consideration for
program improvement, but the observations have no specific regulatory
requirement.
The licensee stated that the observations would be reviewed.
a.
HP Supervisor Job Oversight
The HP Supervisors (licensee and contractor) have not spent an
adequate amount of time inside containment and other radiological
work areas since the start of the Unit 2 outage,
b.
Personnel Contamination Control Work Practices
Many poor radiological work practices employt.1 by workers are not
being observed by the licensee, and when they are observed the
workers are not being critiqued on their poor contamination control
practices.
c,
Use of the-PCM-1 Monitors
Personnel were observed to be turning their face away from the
monitoring screen thus reducing the effectiveness of the monitor to
de c':ct radioactive contamination.
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3.
Open Items Identified During This Inspection
An open item is a matter that_ requires _further review and evaluation by
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the NRC inspector.
Open items are used to document, track, and ensure
adequate followup on matters of concern to the NRC inspector.
The
following open items were identified:
Open' Item
Title
See Paragraph
313/8802-02 &
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368/8802-02
4.
Followup on Previous Inspection Findings (92701 and 92702)
(Closed) Open Item 313/8724-04; 368/8724-04:
Radioactivity in Sanitary
System Filter Beds - This item was identified in NRC Inspection
Report 50-313/87-24 and 50-368/87-24 and involved the detection of
radionuclides in the sanitary effluents.
The licensee had implemented
weekly sampling and analysis of sanitary effluent to and from the filter
beds.
Since Iodine-131 was not found in the sanitary filter beds following
the initial discovery, the licensee believes that the radioiodine in the
efficient was the result of a person using the sanitary facilities at AN0
following a medical administration of iodine for diagnostic purposes.
The
licensee has determined that the most likely source of the Cesium-137 in
the filter beds was due to effluents from the secondary side (steam) of
Unit 1 which still has residual fission products in the system from a
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previous fuel and steam generator integrity problem.
The licensee has been
sampling and accounting for the additional cesium and other fission
products in the semiannual effluent reports.
The NRC inspector reviewed
the licensee's sampling protocols for the sanitary system (monthly
frequency) and documentation of their evaluation of the situation.
(Closed) Violation 313/8631-01; 368/8631-01:
Failure to Provide Timely
Update of Worker Internal Exposures - This violation was identified in NRC
Inspection Report 50-313/86-31 and 50-368/86-31 and involved the failure
to provide a timely update of a worker's exposure to airborne radioactive
materials.
The NRC inspector reviewed the licensee's corrective actions
and their written response to the violation and verified the adequacy of
the licensee's corrective actions.
5.
Outages (83729)
The NRC inspector reviewed the licensee's radiation protection program in
effect during the Unit 2 refueling outage (2R6).
The NRC inspector
reviewed planning and scheduling activities, worker briefings, HP staffing
and manning, control of radiological work activities, qualifications of
contract HP personnel, and compliance with Unic 2 Technical Specification 6.11 and radiological work and industrial safety
instructions.
The licensee's ALARA activities associated with conduct of
the 2R6 outage were also reviewed.
The following specific areas were
reviewed:
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a.
Planning and Preparation
The NRC inspector attended daily planning and scheduling meetings,
held discussions with senior plant managers concerning outage
preparations, and reviewed job preplanning for issuance of Radiation
Work Permits (RWP). The NRC inspector discussed with. licensee
representatives several industrial safety observations associated
with the head removal that should be evaluated.
These items of
concern were:
Lighting in the refueling canal during lifting of the head and
inspection for equipment hang-ups was marginal.' The workers
used hand-held 3-cell flashlights.
Use of the plant paging system was not co'ntrolled and coupled
with its excessive volume, it was very distracting during head
lifting when verbal communication between riggers and
maintenance personnel.was critical to safety.
A maintenance mechanic did not follow instructions to obtain and
wear a safety belt while working over the open refueling pit.
The licensee indicated that the above noted concerns would be
addressed.
The NRC' inspector noted that the licensee had installed a temporary
weather proof passageway and auxiliary offices for HP technicians,
dosimetry. issue and protective clothing issue at the Unit 2 equipment
hatch.
This facility (Alternate Controlled Access) greatly improves
accessibility to the reactor containment and provides greater HP
control over reactor access and work operations.
No violations or deviations were identified.
b.
Training and Qualification of Workers
The NRC inspector reviewed the licensee's program and its
implementation for evaluation and screening of contract HP workers.
The NRC previously reported in NRC Inspection Report 50-313/87-33;
50-368/87-33, an investigation into the circumstances surrounding the
failure of a contract HP technician to properly control a
radiological work operation.
The NRC inspector determined that the
licensee had screened, by testing, approximately 126 contract
technicians and 37 of these technicians (senior and junior
technicians) failed the screening test.
The licensee had a technical
review board evaluate each person that failed and determine if
retesting would be warranted.
Of the 37 that initially failed, 20
were hired after a review of their experience and weaknesses.
The
licensee had hired five contract HP supervisors to assist the
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licensee's inheuse supervisors during the outage.
Each contract
technician completed on-the-job training and was evaluated by a
licensee senior technician prior to being assigned for independent
work responsibilities.
No violations or deviations were identified.
c.
External Exposure Control
The NRC inspector reviewed the licensee's control of radiation and
high radiation areas, hot spot posting,. dose rate evaluations for
steam generator entries, multiple whole body and extremity dosimetry
use, and the conduct of radiological surveys.
The NRC inspector reviewed the radiological controls associated with
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the removal and replacement of the pressurizer spray line, inspection
and maintenance on the two U-tube steam generators, and the reactor
head removal.
The NRC inspector discussed with licensee representatives the
apparent need for HP technicians working as rovers within the reactor
containment to be more attentive in maintaining hotspot and high
radiation area postings.
Two high radiation area perimeter postings
in the lower level of the containment in equipment congested areas
werc noted to be marginal, but within the limitations of the TS.
The
NRC inspector identified to the licensee two hotspot warning labels-
that stated the contact dose rate was a factor of at least 3 times
lower than NRC and licensee radiation surveys indicated.
The licensee
immediately corrected the situations with shielding and updated the
hotspot warning signs.
No violations or deviations were identified,
d.
Internal Exposure Control
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The NRC inspector reviewed the licensee's respirator issue program,
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airborne radioactivity surveys, internal exposure trending and
tracking program, and on-the-job respirator use.
The NRC inspector noted that workers routinely inspected and properly
performed negative fit tests of their respirators prior to use.
The
licensee maintains positive control over issuance and return of
respirators.
The licensee's internal uptake tracking system was
reviewed and found to be well run and only 2 to 3 days lapse before
records are updated to reflect an individual's uptake.
This is a
major improvement over the situation found during the refueling
outage IR7 for Unit 1.
No violations or deviations were identified.
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e.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring
The NRC inspector inspected the licensee's radioactive material
control program for release of materials from radiological work
areas, implementation of contamination control prcctices for major
jobs, cleaning of welds on the exterior of the steam generators, and
the removal of radioactive piping from the. pressurizer system.
The
licensee's use of contamination control containments and partial
enclosures has improved over past outages.
The NRC inspector noted
to the licensee that they were apparently allowing loose surface
contamination levels in work areas to increase to a high level
prior to having the areas decontaminated (100 millirad per hour
smearable).
The NRC inspector discussed with the licensee's
representative the need to improve preplanning and the use of layered
plastic film flooring to aid in the decontamination of areas and to
allow decreased use of respiratory protection equipment and
additional protective clothing.
The NRC inspector reviewed material
release logs at exits from contamination controlled areas.
10 CFR Part 20.201(b) requires that licensees shall make or cause to
be made such surveys as:
(1) may be necessary for the licensee to
comply with the regulations in this part, and (2) are reasonable
under the circumstances to evaluate the extent of radiation hazards
that may be present.
As defined in 10 CFR Part 20.201(a), "survey"
means an evaluation of the radiation hazards incident to the
production, use, release, disposal or presence of radioactive
materials, or other sources of radiation under a specific set of
conditions.
10 CFR Part 20.202 states, in part, that a "Radiation Area" means any
area, accessible to personnel, in which there exists radiation and a
major portion of the body could receive in any 5 consecutive days a
dose in excess of 100 millirems.
This limits equates to a dose rate
of approximately 0.8 mR/hr.
Furthermore, Part 20.203 states, in
part, that each radiation area shall be conspicuously posted with
signs identifying the radiation area.
In addition, TS 6.10 and 6.11 for ANO Units 1 and 2, respectively,
require that procedures for personnel radiation protection shall be
adhered to for all operations involving personnel radiation exposure.
Licensee Procedure 1622.003, "Radiological Posting and Entry
Requirements," requires that in plant radiation areas located outside
of Controlled Access be posted at 0.8 mR/hr.
During a review of facility surveys on February 24-26, 1988, it was
noted that three radiation area surveys conducted on February 14,
1988, and one on February 17, 1988, indicated that areas (Quadrex
decontamination trailer outside perimeter, offices adjacent to the
Unit 1 Controlled Access 386-foot level, and nonradiological
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Instrument and Controls Department work areas above the Maintenance
Shop) normally not classified or posted as radiation areas were
identified as having dose rates under 2.0 mR/hr which would indicate
that they may exceed the posting limit of 0.8 mR/hr.
Furthermore,
the surveys were accomplished with portable radiation survey
instruments that did not have the necessary sensitivity to accurately
measure 0.8 mR/hr of gamma radiation nor did the meter readout allow
for interpretation of values below 1 or 2 mR/hr.
The instruments
used were both high range beta gamma dose rate survey instruments.
These surveys were taken by contract HP technicians and were not
representative of the quality of the majority of the surveys taken at
the plant by both contract and licensee HP technicians.
The NRC
inspector noted also that the surveys in question had been reviewed
by a different licensee HP supervisor as a final stop in the
documentation process.
The NRC inspector noted that sufficient
surveys prior to and after the dates of the questionable surveys
substantiate the fact that the areas were and have been nonradiation
areas, and that the questionable survey results were not the result
of transient radioactive materials.
The failure to properly conduct radiation area surveys is considered
an apparent violation of 10 CFR Part 20.201 requirements.
The
failure to recognize and have posted identified radiation areas is
considered an apparent violation of 10 CFR Part 20.203(b).
These are
considered one violation due to their interrelationship.
(313/8802-01 and 368/8802-01)
No deviations were identified.
f.
Ind,ependent Surveys by the NRC Inspector
The NRC inspector conducted independent radiation surveys of high
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radiation areas, radiation areas, office spaces, and waste
receptacles.
The NRC inspector also verified licensee controls and
periodic inspection records for very high radiation areas.
No violations or deviations were identified,
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ALARA Program
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The NRC inspector reviewed the licensee's ALARA program.
The NRC
inspector noted that the licensee was providing 24-hour ALARA
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technician support for resolution of problems concerning radiological
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job requirements and temporary shielding installation.
The licensee
had provided an ALARA technician for interfacing with Work Control
Center Personnel for early review of maintenance work packages for
determining Radiation Work Permit requirements.
The NRC inspector
observed senior plant managernent interfacing with the ALARA
coordinator on resolving major radiological problems involving
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removal of the reactor head.
The licensee was found to be closely
' tracking job performance based on person-rem exposure.
No violations or deviations were identified.
h.
Staffing
The NRC inspector reviewed the licensee's HP staffing for the outage
and determined that it~was adequate, but was stretched thinly'during
some instances when maintenance work scheduling exceeded the
available HP manpower.
No violations or deviations were identified.
6.
Control Roon, ilabitability
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The NRC inspector reviewed the licensee's corrective actions taken in
response to NRC Memorandum, "Survey of ANO Units 1 and 2 Control Rooms,"
dated July 28, 1987 (J. Hayes, NRR to R. Lee, NRR).
The licensee had initiated a project to conduct a detailed review of
control room habitability systems.
The licensee had issued at least one
Licensee Event Report (LER 87-08, concerning air leakage into the control
rooms) due to this review project.
The licensee is drafting a response to
the NRC regarding their review of the NRC information concerning the ANO
control rooms which was transmitted to the licensee on or'about August 1,
1987.
The NRC inspector obtained procedures for testing and surveillance of the
control room ventilation and safety systems.
Due to the extensive amount
of material presented for review, this item will be considered an'open
item pending further NRC review for close out of the NRC's concerns in
this area.
(313/8802-02; 368/8802-02)
No violations or deviations were identified.
7.
Exit Interview
The NRC inspector met with the NRC resident inspector and licensee
representatives denoted in paragraph 1 on February 26, 1988, and
summarized the scope and inspection findings.