ML20203D461
| ML20203D461 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/27/1986 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203D454 | List: |
| References | |
| 50-313-86-16, 50-368-86-16, IEIN-84-59, IEIN-84-60, IEIN-84-61, IEIN-85-042, IEIN-85-060, IEIN-85-087, IEIN-85-42, IEIN-85-60, IEIN-85-87, IEIN-86-024, IEIN-86-24, NUDOCS 8607210222 | |
| Download: ML20203D461 (11) | |
See also: IR 05000313/1986016
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50 313/86-16
Licenses:
50-368/86-16
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)
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Inspection At:
AN0 Site, Russellville, Pope County, Arkansas
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Inspection Conducted: -May 19-23, 1986
Inspector:
14
ihA184/
H. Chaney, Radiation Spe /ialist, facilities
Date
Radiological Protectioh Section
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Approved:
//f(d
(b/l86/
3. Murray, Chief, Faci /ities Radiological
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Protection Section /
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Inst.ection Summary
Inspection Conducted May 19-23, 1986 (Report 50-313/86-16; 50-368/86-16)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiation
protection program (RP) including:
external and internal radiation exposure
controls, respiratory protection, contamination control, radiological. surveys,
radioactive material controls, radiation protection facilities, and
preparations for tne upcoming Unit 2 refueling outage.
Results: Within the areas inspected, one violation (see paragraph 3) and no
deviations were identified.
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8607210222 86071ib
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DETAILS
1.
Persons Contacted
- J. M. Levine, Director, Site Nuclear Operations
- E. C. Ewing, General Manager, Plant Support
- D. ~J. Wagner, Health Physics (HP) Superintendent (Acting)
- B. L. Bata,-Quality Assurance (QA) Engineer
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- S. Quennoz, General Manager,' Plant Operations
- J. D. Vandergrift, Training Manager
- L. W.'Humphrey, General Manager, Nuclear Quality
- L. W. Schempp, Quality. Control (QC) Superintendent
- J. H. Montgomery, Human Resources Supervisor
- D. B. Lomax, Plant Licensing Supervisor
- P. E. Campbell, Plant Licensing Engineer
M. J. Bolanis, HP Specialist
F. H. Chilcoat, Instruments and Controls (I&C). Technician
R. E. Green, HP Dosimetry Supervisor
R. D. Deal, Dosimetry Technician
L. E. Qualls, Dosimetry Technician
J. S. Fancher, HP Technician
T. R. Smith, HP Supervisor
B. C. Burchard, HP Supervisor
D. M. Dobbins, Data Processing Specialist
N. R. Williams, HP Technician
D. G. McCaslin, HP Technician
D. W. Akins, Radwaste Supervisor
H. N. Bishop, Assistant Radwaste Supervisor
I. Mosquito, Respiratory Protection Trainer
R. E. Stell, HP Technician
W. L. Hada, HP Supervisor
D. L. Helm, HP Specialist (ALARA Coordinator)
J. Waid, Supervisor, Technical Specialisc Training
,
Others
- W. D. Johnson, Senior NRC Resident Inspector
C. C. Harbuck, NRC Resident Inspector
- Coaotes those present at the exit interview on May 23, 1986.
The NRC inspector also interviewed other licensee employees including
QA/QC, warehouse, toolroom, and contracted HP personnel.
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2.
Inspector Observations
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The following are observations the NRC inspector' discussed with'the
licensee during the exit meeting on May 23, 1986. These observations are
neither violations nor unresolved items. These items were recommended for
licensee consideration for program improvement, but they. nave no specific
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regulatory requirement.
a.
Legibility of Radiation Work Permits (RWP) - Special radiation
protection instructions on RWPs and ALARA evaluations were found to
be illegible.
(see paragraph 3 for details)
b.
Airborne Radioactivity Uptake Calculations - The licensee had not
implemented a procedure for assessing the radioactive material uptake
of personnel in terms of Maximum Permissible Concentration - hours
based on bioassay results.
(see paragraph 4 for details)
c.
Snelf Life of Respiratory Protection Equipment - The licensee's
respiratory protection equipment (RPE) QC inspections do not
adequately address the periodic review of chemical canisters,
lubricants, and thread sealers for shelf life expiration.
(see
paragraph 4.b for details)
d.
Marking of Breathing Air Gas Cylinders - Several cylinders containing
breathing air needed to be remarked to indicate their contents.
(see
paragraph 4.b for details)
e.
Low-Level Radioactive Waste Storar
'3uilding - The radioactive
liquid waste sump has potential unmonitored release pathways.
(see
paragraph 6 for details)
3.
External Radiation Exposure Control and Dosimetry
The licensee's RP program was reviewed for compliance with the commitments
contained in the Unit 1 Updated Safety Analysis Report (USAR) -
Section 11.2.6.1, and Unit 2 USAR-Section 12.3.3; the requirements of
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Unit 1 Technical Specificiation (TS) 6.10, 6.11, 6.12, and Unit 2 TS 6.11
and 6.13; the requirements of 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; the recommendations of NRC Inspection and Enforcement (I&E)
Infonnation Notices 86-24, 85-87, 85-60,-85-42, 84-61, 84-60, 84-59; the
recommendations of HRC Regulatory Guides (RGs) 8.2, 8.4, 8.7, 8.8, 8.13,
8.14, and 8.28; and the recommendations of industry standards
ANSI N13.11-1983, N13.5-1972, and N13.27-1981.
The NRC inspector reviewed and inspected: dosimetry equi
control procedures (whole body, extremity, skin and eyes)pment; exposure
- equipment
operating procedures; representative records of exposures for permanent
ANO and AP&L employees, visitors, and contractors; high radiation area
posting and controls; and compared dosimetry requirements referenced on
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radiation work permits (RWP) to those observed at worksites.
The'NRC
inspector reviewed the implementation of a computerized exposure control.
and exposure records systca, and a new state-of-the-art personnel
dosimetry system.
The NRC inspector determined.that the~ licensee had.
included the information contained in I&E Information Notice 85-42 to
their proposed dosimetry system.
The NRC inspector also noted that the
licensee was participating in a routine QA proaram with an offsite
laboratory to compare their current personnel dosimetry system with the
criteria of industry standard ANSI 13.11-1983.
The licensee's inventory'
and capab.lities of personnel dosimetry equipmer;t maintained in emergency
kits (E-kits) were inspected.
Procedures reviewed during this inspection
are listed in the attachment to this inspection report.
The NRC inspector reviewed the licensee's processing of personnel dosimetry
for compliance with ANO procedures and TS requirements.
During a review
of one of the two dosimetry processing stations at ANO on.May 21, 1986,
the NRC inspector noted that the dosimetry technicians were using an
out-of-date procedure for establishment of the QC parameters for the
thermoluminescent dosimeter (TLD) reader.
TS 6.10 (Unit-1) and 6.11
(Unit-2) require that procedures be maintained and adhered to for all
operations involving personnel radiation exposure.
The dosimetry
technician was found to be using a unofficial copy of Revision 4 to AN0
Operations Procedure 1632.020, "Harshaw 2271 TLD System Setup," for
setting the QC parameters of the TLD prcoesssing equipment (at the ANO
Nuclear Training Center) when Revision 5 had been in effect since March 18,
1986. When this was brought to the attention of the dosimetry technician,
the technician immediately obtained an unofficial copy of Revision 5 to
the procedure and verified that all processing parameters were still
valid.
The NRC inspector also noted, that eventhough the completed QC
setup data sheets had a place for signifying a review by the dosimetry
supervisor, data sheets had not been reviewed since before March 1, 1986.
The use of obsolete procedures for establishing TLD operating parameters
is an apparent violation of TS 6.10 and 6.11 for Units 1 and 2.
(50-313/8616-01 and 50-368/8616-01)
During a review of several RWPs and ALARA job reviews, it was noted that
the special handwritten instructions appearing on both types of documents
were illegible. The NRC inspector emphasized to licensee representatives
that worker comprehension of written instructions was paramount to
implementation of effective radiological controls over work operations.
The licensee's representatives stated that this problem would be resolved
by the new computerized exposure control system, in that, special RWP
instructions would be typed.
The licensee indicated that, in the meantime,
instructions would be given to RWP writers to ensure that RWPs were more
legible.
The NRC inspector observed prework briefings and reviewed proposed
radiological controls for the transfer of a two curie Cesium-137 source
from a storage container into an automated TLD irradiator.
No deviations s're identified.
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4.
Internal Radiation Dosimetry and Exposure Control
The licensee's internal radiation exposure control program, including
airborne radioactivity monitoring / sampling and respiratory protection
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program, was reviewed for compliance with the commitments in Unit 1
USAR-Sections 11.2.6 and 11.3.2.3, and Unit 2 USAR-Sections'12.2.4 and
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12.3.3.2; the requirements of Unit 1 TS 6.10 and Unit 2 TS 6.11;
the
requirements in 10 CFR Parts 19.12, 19.13, and 20.103, 201, 203, 405, 407,
20.408, and 20.409, and 29 CFR Part 19.10; the recommendations of' industry
standards ANSI 13.1-1969, N343-1978, Z88.2-1980, NUREG-0041, and RG 8.2,
8.7, 8.8, 8.9, 8.15, 8.20, and 8.26.
The NRC inspector reviewed the licensee's corporate policies, programs, and
activities involving routine and emergency aspects of the internal
dosimetry and exposure controls.
a.
Internal Dosimetry
The NRC inspector reviewed internal radioactive assessment procedures,
in-vitro bioassay equipment (two whole body counters), and a
computerized assessment program.
The licensee documentation logs for
equipment calibration and daily response checks were inspected.
During a review of the records used by the HP department to track
personnel exposures to radioactive materials and determine whether or
not whole body counting is required, it was noted that an error was
made in one calculation involving the degree of exposure (in units of
maximum permissible concentration-hours (MPC-hr)) incurred by a
worker during April 26-27, 1986.
The licensee's procedures 1622.015,
" Bioassay Sampling Program," and 1609.010, "MPC-hour and Staytime
Calculations," require that personnel be given a whole body count
when they exceed 2 MPC-hr of exposure during any day /24-hour period.
MPC-hr tracking records revealed that following an internal exposure
of approximately 1.1 MPC-hr, on April 26, 1986, at 9:30 p.m. an
employee received another exposure of approximately 1.8 MPC-hr, on
April 27, 1986, at 9:30 a.m.
The HP supervisor making the entries
did not sum the two entries.
This error led to the worker being
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excluded from being monitored for internal radioactivity eventhough
the worker's total estimated exposure for the previous 24-hour period
was 2.9 MPC-hr.
Discussions with the supervisor and other licensee
representatives disclosed that the supervisor mistakenly assumed that
the use of calendar days was meant in the procedures and not a
continuous 24-hour period. The NRC inspector reviewed approximately
60 other entries and did not observe any other errors.
The licensee
immediately corrected the error, arranged for the subject worker to
be given a whole body count, reinstructed the supervisor in the
proper method for tracking MPC-hr expnsures, revised the MPC-hr
tracking form so that each entry included the time of the incurred
exposures, provided definitions on daily and weekly exposure criteria,
and provided for better supervisory review of the entered data.
This
problem appears to be an isolated case and not an indication of a
general breakdown of the program.
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The licensee's termination report involving uptake of radionuclides
and WBC results is being modified to address NRC Form 439 changes
that were recently recommend by the NRC. .The licensee stated that
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there had been no significant or unique radionuclide uptakes that
have necessitated the use of indirect (in-vitro) bicassay methods.
b.
Respiratory Protection
Tne NRC inspector reviewed the licensee's occupational radiological
respiratory protection program involving:
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management policies on respiratory protection equipment (RPE)
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use,
implementing procedures,
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- qualifications of personnel-responsible for program
implementation,
training,
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maintenance,
determination of user physical fitness,
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fit testing,
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certification,
QC and testing,
program review and oversight,
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inventory control,
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breathing air standards and certification,
compressor qualifications,
RPE dedicated to emergency response,
radiological surveys c' permanently installed plant breathing
air systems,
selection, issuance and return of RPE,
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- radiological su'rveying of RPE,
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dscontamination and sanitizing of RPE,
inspection,,of stored RPE,
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retesting breathing air cylinders and filter cartridges, and
use of chemical canisters.
The licensee's actions taken regarding I&E Information Notices 84-24,
84-60, 85-60, and 85-87 were reviewed.
The licensee has an
established program to evaluate each notice.
The NRC inspector noted
that the licensee's internal correspondence regarding I&E Information
Notices did not address Notice 84-24, " Physical Qualifications of
Respiratory Protection Users." However, the NRC inspector determined
that the licensee's medical qualification program for RPE users
adequately addressed the requirements of 10 CFR Part 20.103.
The NRC inspector also reviewed the licensee's respiratory program
concerning identification of airborne radioactive concentrations via
grab sampling (including breathing zone sampling) and continuous air
monitoring.
The licensee's paseous and particulate sampling programs
for routine and emergency concitions involving alpha and beta gamma
concentrations (including trit 0m and Iodine-131) were reviewed.
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Records of air sampling activities were reviewed and found complete,
and able to identify individusi radioisotopes at/or below the limits
stated in 10 CFR Part 20, Appendix B.
The NRC inspector discussed with the licensee several areas that could
be improved.
It was noted that the quarterly HP department QC sampling
(procedure 1609.012, " Respiratory Protection Program Evaluation") of
RPE did not provide for the inspection of RPE (chemical canisters and
cartridges) and RPE maintenance materials (thread sealer and lubricants)
for shelf-life.
Also, it was noted that several breathing air
cylinders were in need of relabeling as to their contents.
The NRC
inspector also noted that the non-radiological respiratory protection
program, which is used on occasion within radiologically controlled
areas, does not appear to satisfy the requirements of the safety and
,
health standards promulgated by the Occupational Safety and Health
Administration (OSHA) in 29 CFR Part 19.10, and other pertinent
)
industry standards.
Areas of concern include training of personnel
in equipment selection, control over equipment issue and use, and fit
testing of equipment.
The RPE involved half-face filtered masks and
chemical cartridges. Tne aforementioned concerns were referred to
the Regional OSHA office in Dallas, Texas, for further action.
These
actions are in accordance with guidance contained in NRC Enforcement
and Inspection Manual Chapter 1007.
)
5.
Control Radioactive Materials (RAM) and Contamination, and Radiological
Monitoring
The licensee's programs for the control of RAM and contamination,
radiological surveys and monitoring were reviewed for compliance with the
commitments contained in the Unit 1 USAR-Sections 11.2.6 and 11.3.1, and
Unit 2 USAR-Sections 12.1.3.4, 12.2.4, 12.3.3, and 12.4.1; the
requirements in Unit 1 TS 4.14, 6.10, and 6.11, and Unit 2 TS 3/4.7.9,
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6.11, and 6.13; the requirements in 10 CFR Parts 19.12, and 20.4, 20.5,
20.201, 20.203, 20.207, 20.209, 20.301, 20.401, 20.402, and
NUREG-0737-Item III.D.3.3; and the recommendations of I&E Information
Notices 84-25, 85-92, and 86-23.
The NRC inspector inspected the licensee's radiological survey program
including:
areas surveyed (lunch rooms, tool rooms, locker rooms, and
normally non-radioactive plant systems), frequency of surveys, detail of
surveys, documentation and supervisory review of completed surveys, and
storage of completed survey records.
The licensee's radiological survey
program was found to be well maintained.
The NRC inspector reviewed the
licensee's surface contamination and airborne contamination survey program
for the ability of the licensee to qualitatively and quantitatively
identify failed-fuel related radioactivity in plant areas, including
Iodine-131 during emergency situations.
The NRC inspector also conducted
confirmatory measurements of licensee posted radiation and high radiation
areas.
Radiological worker conduct and contamination control practices
were also reviewed during plant area inspections.
The licensee's radiological work area review program and high radiation
area posting (including a functional door check) programs were reviewed.
The NRC inspector discussed with licensee representatives the depth of
control exercised over the Unit 1 secondary steam system when certain
portions were opened.
This system had become contaminated during a failure
of steam generator tubes.
The licensee's posting of the Unit-1 secondary
systems appeared to be complete and in accordance with the requirements of
Procedures and records of the licensee's activities
involving procurement, receipt, storage, and accountability of radioactive
materials / sources was inspected.
Several portable radiological survey
instruments and their operating procedures were inspected for current
calibration.
The NRC inspector also reviewed the facts involveo in the
licensee's telephonic report, on December 3, 1985, to the NRC Regional
Office of a possible lost source.
The licensee's subsequent investigation
determined that an instrument technician had in appropriately stored the
low-activity source onsite (over the weekend) when he found the normal
source storage facility locked.
The selected interim storage location
did not create any exposures to personnel or improperly posted areas.
The
sealed radioactive source consisted of approximately 80 microcuries of
The licensee had reevaluated their control over sources and
reduced the number of auxiliary source storage and issue locations.
No violations or deviations were identified.
6.
Radiological Control Facilities and Equipment / Instruments
The licensee's facilities for radiological protection activities during
routine and emergency situations were reviewed for compliance with
commitments contained in the Unit 1 USAR-Sections 11.3.2, and 12.3.1, and
the Unit 2 USAR-Sections 12.3.2, 12.4.2, and 13.3; the requirements in
Arkansas Nuclear One Emergency Plan (ANO-EP)-Tables 4A, 48, 4E, 4F, 4G,
and 4H; Units 1 and 2 operating license condition regarding monitoring
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ability for Iodine-131 during reactor accidents; Unit 1 TS 6.5 and Unit 2
TS 6.5.2.8.e; and the recommendations of RG 1.97, 8.8, 8.25, NUREG-0041,
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and NUREG-0654/ FEMA-REP-1.
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The NRC inspector inspected the facilities for ingress and egress from
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radiological controlled areas, temporary work facilities, and assembly areas
used during activation of the ANO-EP.
Facilities for HP technicials,
protective clothing donning and removal, protective clothing sorting and -
storage, radiological instrument storage and calibration (including
segregation of ready-for-use instruments from uncalibrated instruments),
and the computer controlled instrument inventory and calibration / maintenance
surveillance system.
Respirator protection equipment issue, repair,
training, and mask fit test facilities were also reviewed.
The licensee's
dedicated stock of emergency equipment in emergency-kits in the:
control
rooms, operational support center, offsite emergency operations facility,
onsite first aid room, and the Russellville, Arkansas St. Mary's Hospital,
were inspected for proper inventory and compliance with plant inventory
procedures.
All emergency-kits contained the required radiological
monitoring equipment, expendable radiological surveying supplies,
respiratory protection equipment (including iodine canisters for full face
respirators), decontamination supplies, first aid kits, and procedures to
perform required emergency monitoring functions, including onsite surveys
and radiological habitability verifications of selected emergency
facilities.
The licensee's warehouse inventory of radiological and
respiratory protection equipment and expendable supplies were inspected.
The NRC inspector discussed with licensee representatives their preparations
for the upcoming refueling outage for Unit-2.
The licensee was evaluating
dose reduction methods to be employed during steam generator and pressurizer
work operations.
The NRC inspector noted that the licensee maintained
full scale mockups of their steam generators onsite for training of
personnel involved in steam generator tube inspection and repair.
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During an inspection of the newly built onsite low-level radioactive waste
storage building, it was noted that the drainage system for collection of
liquid leakage from stored wastes in the building involve a potential
unmonitored pathway to the environment.
The NRC inspector noted that a
potential path of potentially radioactive liquids existed from the
collection systems pumpdown and diverting valve manifold (located in the
truck bay) to an unmonitored storm / sewer drain system opening, which is
also within the truck bay.
This valve manifold was noted to consist of
approximately nine bolted bonnet and flanged manually operated valves for
the flow control, blowdown, and pumpdown of the system.
This valve
complex was not provided a leakage collection system or impoundment for
leakage from the uncapped valve openings or their flanged joints.
Also,
the main pumpdown valve for the 5000 gallon sump associated with the
system extends out into the truck bay and is not provided any protection
from contact with vehicular movement within the area.
At the time of the
inspection, the facility was not operational and no radioactive waste
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had been moved into the facility.
The licensee stated that the NRC
inspector's observations would be reviewed prior to use of the building.
No violations or deviations were identified.
7.
Exit Interview
The NRC inspector met with the licensee's representatives and the NRC
resident inspector identified in paragraph 1 of this report at the
conclusion of the inspection on May 13, 1986.
The NRC inspector
summarized the scope and the results of the inspection.
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