ML20205N721

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Insp Repts 50-313/86-04 & 50-368/86-04 on 860127-31. Violations Noted:Emergency Response Training Inadequately Provided Per Listed Discrepancies & Radiation Monitoring & Sampling Equipment Inadequate
ML20205N721
Person / Time
Site: Arkansas Nuclear  
Issue date: 04/11/1986
From: Terc N, Yandell L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205N701 List:
References
50-313-86-04, 50-313-86-4, 50-368-86-04, 50-368-86-4, NUDOCS 8605020267
Download: ML20205N721 (6)


See also: IR 05000313/1986004

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APPENDIX B

U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report:

50-313/86-04

Licenses:

DPR-51

50-368/86-04

NPF-06

Dockets:

50-313

50-368

Licensee:

Arkansas Power & Light Company

P. O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One (ANO)

Inspection At:

Russellville, Arkansas

Inspection Conducted: January 27-31, 1986

Inspector:

(hrd}b

M

4[t/M

Neiiien M: Terc, Emerge

Preparedness Analyst,

04te '

Emergency Prepared

s and Safeguards

Programs Section

Accompanying personnel:

Mark I. Good, PNL

Approved:

bdi

4/u//f

L. A. Yandell, Chief, Emergency Preparedness

Da'te

and Safeguards Programs Section

Inspection Summary

Routine Inspection Conducted January 27-31, 1986 (NRC Report 50-313/86-04 and

50-368/86-04)

Areas Inspected:

Routine, unannounced inspection of the licensee's emergency

preparedness training program, including followup of previously identified

items, personnel proficiency, and training records.

Resul t.s:

Within the area inspected, two violations were identified (failure to

provide adequate training paragraph 3; inadequate equipment and procedures-

paragraph 3).

Sixteen open items from previous inspections were closed.

8605020267 860418

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DETAILS

1.

Persons Contacted

AP&L

  • B. A. Baker, Operations Manager
  • T. C. Baker, Technical Analysis Superintendent
  • B. L. Bata, Quality Assurance Engineer
  • D. W. Boyd, Emergency Planning Coordinator, ANO
  • P. Campbell, Plant Licensing Supervisor
  • T. H. Cogburn, General Manager Nuclear Services
  • J. T. Enos, Manager Nuclear Engineering and Licensing
  • R. C. Evans, Manager Engineering Supply Training
  • R. E. Harris, Training Coordinator
  • D. Howard, Special Projects Manager
  • L. W. Humphrey, Administrative Manager
  • R. E. Jackson, Administrative Training Supervisor
  • J. M. Levine, Director Site Nuclear Operations
  • D. B. Lomax, Plant Licensing Supervisor
  • J. McWilliams, Operations Superintendent
  • J. T. Pugh, Lead Trainer
  • J. D. Vandergrift, Training Manager
  • F. P. Van Buskirk, Emergency Planning Coordinator, ANO
  • J. R. Waid, Training Supervisor
  • D. Ward, Shift Supervisor

NRC

  • C. C. Harbuck, Resident Inspector, ANO
  • J. E. Gagliardo, Reactor Projects Branch Chief, USNRC-IV
  • W. D. Johnson, Senior Resident Inspector, ANO

During the inspection, the NRC inspectors also contacted other licensee

personnel such as:

shift operation supervisors and shift staff

assistants, shift health physics and chemistry technicians.

  • Denotes those present during the exit interview.

2.

Licensee Action on Open Items from Previous Inspections

(Closed) (313/8122-90; 368/8121-90):

The NRC inspectors noted that

training of offsite emergency response personnel had been incorporated in

the Emergency Plan and in procedure TP 1063.21, " Emergency Response

Training Program."

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(Closed) (313/8211-26; 368/8209-26):

The NRC inspectors noted that procedure

EPIP 1904.07, "Offsite Dose Projections," implemented on January 27, 1983,

'

-incorporated integrated projected radiation doses in addition to dose

rates.

(Closed) (313/8211-89; 368/8209-89):

The NRC inspectors noted that the

licensee did not intend to use data from state monitoring teams in their

calculations.

(Closed) (313/8319-01; 368/8319-01):

The NRC inspectors reviewed the

10 CFR 50.54(t) Quality Assurance of emergency prep..edness for 1985 and

noted that interfaces with the state had been evaluated.

.(Closed) (313/8408-07; 368/8408-07 and 313/8502-03; 368/8502-03):

The NRC

inspectors noted that NRC Report Nos. 313/85-25 and 368/85-26 had documented

that the evacuation of the Emergency Operations Center was timely.

(Closed) (313/8408-09; 368/8408-09):

The NRC inspectors noted that coordination

of state offsite teams was made by the state authorities (See also response

to 313/8211-09).

(Closed) (313/8408-11; 368/8408-11):

The NRC inspectors noted that

medical kits for treating injured contaminated persons were provided by

June 1, 1984.

(Closed) (313/8423-01; 368/8923-01): The NRC inspectors noted that a

remedial drill to verify the proficiency of the shift supervisor and the

shift administrative assistant was conducted.

(Clostd) (313/8423-02; 368/8423-02):

The NRC inspectors noted that

-quarterly drills had been established and implemented to upgrade emergency

response training of operations personnel in the areas of emergency

detection, classification, notifications, and protective action

recommendations.

(Closed) (313/8502-02; 368/8502-02):

The NRC inspectors determined that

implementation and use of form QAP-13 was revised on July 22, 1985, to

incorporate reference to the elements of 10 CFR 50.54(t).

(Closed) (313/8502-04; 368/8502-09):

The NRC inspectors reviewed

documentation showing that an unannounced shift augmentation drill was

conducted on December 16, 1985.

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(Closed) (313/8510-04; 368/8510-04):

The NRC inspectors noted that revised

dose projection procedures contained correction factors derived from field

team radiation measurements.

(Closed) (313/8510-05; 368/8510-05):

The NRC inspectors noted that the

recovery mode was demonstrated in drill and observed by NRC in October

1985 (see NRC Report Nos. 50-313/8510-25; 50-368/8510-26).

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(Closed) (313/8510-08; 368/8510-08):

The NRC inspectors noted that procedures

and forms were incorporated in emergency cabinets and kits and were

included in the document control system.

(Closed) (313/8510-10; 368/8510-10):

The NRC inspectors noted that the

licensee changed their communication scheme while donning self contained

breathing apparatus.

Now they rely on portable transceivers applied to

their throats.

No violations or deviations were noted in this area.

3.

Knowledge and Performance of Duties (Training)

l

The NRC inspectors reviewed Section 0 of the Emergency Plan for Arkansas

Nuclear One, and En:ergency Plan Administration Procedure No.1063.1,

" Emergency Response Training Program." The NRC inspectors noted that this

procedure was presently undergoing an extensive revision. A total of 25

master training record printouts and a sampling of 10 records in microfilm

were reviewed to verify the accuracy and consistency of the training

records.

In addition, the inspectors made a detailed review of 3 out of

29 existing lesson plans.

The NRC inspectors also conducted interviews and walkthroughs with

on-shift emergency response elements such as shift supervisors and

administrative assistants, shift health physics and chemistry technicians.

The NRC inspectors tested the performance of four shift supervisors and

four administrative assistants representing a total of four different

shifts, by means of individual emergency response scenario walkthroughs in

the control room.

Each walkthrough lasted approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The

same accident scenario was used for each shift.

The scenario presentee by

the NRC inspectors required classification of emergency events, initial

notifications and dose projections.

In addition, the NRC inspectors

interviewed six on-shift health physics technicians and three chemists who

were responsible to perform dose calculations.

The health physics

technicians were presented with a scenario designed to test their ability

in determining both the habitability of the control room, and the

radioiodine content of a radioactive plume.

Based on the above activities, the NRC inspectors made the following

findings:

o

Health physics technicians that would have on-shift. assignments were

unable to perform two main tasks they would be responsible for during

accident conditions.

o

The NRC inspectors determined that all six health physics technicians

interviewed ignored technical criteria necessary to establish

habitability conditions in the control room and as a consequence

failed to determine protective action guides for personnel in the

control room during accident conditions.

These technicians failed to

recognize that one of their major responsibilities was the protection

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of emergency workers, and had no idea of the priorities and nature of

immediate actions required from them.

This indicated that if the

shift supervisor was too busy to direct them, they would be unable to

perform their duties.

o

The second task required by the NRC inspectors from the health

physics technicians involved the ability to determine whether a

radioactive plume contained radioiodine.

All of six technicians

failed to perform this task because they were unable to adequately

interpret sample results.

The above examples of insufficient training are an apparent violation

against the requirements of 10 CFR 50.47(b)(15), which states that

" Radiological emergency response training is provided to those who may be

called on to assist in an emergency."

(313/8604-01; 368/8604-01).

While conducting a procedure review, the NRC inspectors made the

following findings:

o

Procedures 1905.002 "Offsite Emergency Monitoring," 1205.030

" Airborne I-131 determination using MS-2/ SPA-3," 1905.031 " Airborne

I-131 determination using an RM-14/HP-210," and 1905.032 "Use of

ND-60 Multichannel Analyzer" offered no guidance for determining

<hether the individual taking the airborne sample in the field was

immersed in the radioactive plume.

Several technicians stated that

they needed walkthroughs on back shifts and more in depth training on

tasks involving their main emergency duties,

o

The NRC inspectors further noted that instrumentation presently in

offsite emergency kits appeared to be inadequate to establish whether

offsite air sampling is being performed within the radioactive plume.

The above examples of inadequate procedures and inadequate

instrumentation are an apparent violation against the requirements of

10 CFR 50, Appendix E, Part IV.E(2), which states that " Adequate

provisions shall be made and described for equipment used to

determine the release of radioactive materials to the environment."

(313/8604-02; 368/8604-02).

The following are observations the NRC inspectors called to the licensee's

attention.

These observations are neither violations nor unresolved

items. These items are recommended for licensee consideration for program

improvement, but they have no specific regulatory requirement.

The

licensee indicated that these items would be reviewed.

o

Some emergency response personnel had not received all required

training.

For example, one communications manager was missing the

communications lesson; one shift supervisor was missing the

Protective Action Recommendations lesson; and one shift

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administrative assistant was missing the Protective Action

Recommmendation lesson.

The NRC inspectors could not determine from

records and interviews whether the individuals had not received the

training .or whether the training documentation had been misplaced or

lost.

Training lecture documentation for three other emergency

response persons which included 22 lectures was not available in the

master training record files.

Documentation for the apparent missing

records was produced at the end of the inspection by searching other

files.

This indicates that a programmatic deficiency exists in the

licensee's record keeping system.

o

Other errors were found in the training record keeping system such as

incorrect logging and posting, incorrect microfilm numbers, missing

lessons, double entries of lessons and title inconsistencies.

Of the

25 records examined, 9 records had missing documentation and

administrative errors.

o

Administrative Procedure No. 1063.21, Revision 6, "En.ergency Response

Training Program," which governs the licensee emergency response

training program, failed to specify requirements for a periodic

review of training records.

o

Emergency response personnel who participated in control room

walkthroughs performed classification and notifications in a correct

and timely manner.

Notification forms were completed with few

errors. Proper signatures and authorizations were obtained prior to

release of information.

Emergency procedures were used efficiently

for emergency plan actions.

Protective action recommendations made

were based on plant conditions and were appropriate and timely.

No other violations or deviations were identified.

4.

Exit Interview

The exit interview was held on December 13, 1985.

The exit interview was

conducted by Mr. Nemen M. Terc, Emergency Preparedness Analyst, with

Messrs. J. E. Gagliardo, Reactor Projects Branch Chief, W. D. Johnson, NRC

Senior Resident Inspector, and C. C. Harbuck, NRr Resident Inspector in

attendance.

The licensee was represented by Mr.

.J. M. Levine, Director,

Site Nuclear Operations and his staff.

The licensee was given an oral summary of the NRC inspectors findings,

observations and comments.

The NRC inspectors identified two violations

described above (see paragraph 3 of this report).

In addition, the NRC

inspectors noted that 16 improvement items identified in previous

inspections were closed.