ML20214K254

Insp Rept 50-368/86-17 on 860623-27.Violation Noted:Failure to Follow Procedures for Handling Radioactive Matl Removed from Reactor Containment.Deviation Noted:Failure to Post or Implement Positive Access Controls to Fuel Element Tube

ML20214K254
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/11/1986
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214K245	List: ML20214K243 ML20214K247 ML20214K251 ML20214K254
References
50-368-86-17, NUDOCS 8608210005
Download: ML20214K254 (10)

See also: IR 05000368/1986017

Text

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APPENDIX C

U.S. NUCLEAR REGULATORY COMISSION

REGION IV

-NRC Inspectio'n Report: 50-368/86-17- License: NPF-6

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Docket: 5'0-368

Licensee: Arkansas Power and Light Company

P. O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One, Unit 2

Inspection . At: AN0 Site, Russellville, Pope County, Arkansas

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Inspection Conducted: June 23-27, 1986

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Inspector: 8h 2

H. Chaney Madiation Specialfist, Facilities Date

RadiologicalProtectionS(ction

Approved: t #

B' Murray, Chief, Fa(ilities Radiologic ' Date

Protection Section

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Inspection Summary

Inspection Conducted June 23-27, 1986 (Report 50-368/86-17)

Areas Inspected: -Routine, unannounced inspection of the radiation protection

program for the Unit 2 refueling outage.

Results: Within the areas inspected, one violation (multiple examples.of

failure to follow procedures, paragraphs 7 and 11) and one deviation (failure to meet

a commitment, paragraph 10) were identified.

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8602210005 86091S

PDR ADOCK 05000368 4

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DETAILS '

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1. Persons Contacted

AP&L

• E. C. Ewing, General Manager, Plant Support

• D. J. Wagner, Health ~ Physics'(HP) Superintendent-(Acting)

• D. R. Howard, Special Projects Manager

• J. McWilliams, Maintenance Manager

• L. W. Humphrey,' General. Manager Nuclear Quality-

• D. B. Lomax, Plant Licensing Supervisor-

• P. E.- Campbell, Plant Licensing Engineer

• E. E. Bickel, HP Specialist ,

F.- H. Chilcoat, Instruments and Controls (I&C) Technician

R. E. Green, HP Dosimetry Supervisor

L. E.-Qualls, Dosimetry Technician

J. S. Fancher, HP Technician

T. R. Smith, HP Supervisor

B. C. Burchard, HP Supervisor

D. W. Akins,'Radwaste Supervisor

I. Mosquito, Unit 2 Outage Coordinator

W. L. Hada, HP Supervisor

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

J. Waid, Supervisor, Technical Specialist Training-

M. R. McIntosh, HP Supervisor

A. Massengale, Maintenance Supervisor

Others

• W. D. Johnson, Senior NRC Resident Inspector

R.. Drake, Applied Technology of Barnwell Inc. (ATBI) HP Supervisor

G. Conley, ATBI HP Technician

A.- Murray, ATBI HP Technician

S. Townsend, ATBI HP Technician

R. Levy, Nuclear Systems Service (NSS) Technician

R. Kight, NSS Technician

D. Baxter, NSS Technician

R. Couch, Combustion Engineering Technical Representative

* Denotes'those present at the exit interview on June 27, 1986.

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The NRC inspector also interviewed other licensee employees including

quality assurance / quality control and contracted HP personnel.

2. Licensee Actions on Previous Inspection Findings

(Closed) Open Item (313/8313-04 & 368/8313-04): Calibration of Air

Samplers - This item was previously discussed in NRC Inspection Report

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50-313/83-13 and 50-368/83-13 and involved theJlack.of an air sampler

calibration program that"satisfled_~the7ecommendations of NRC' Regulatory'

Guide (RG).8.25. The' licensee had revised procedure.1313.003,-and~

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' developed procedures 1313.037 and 1313.038 that implemented the:

recommendations of'RG 8.25. This item is considered closed. '

J ~ 3. Inspector Ob'servations

The following are observations the NRC inspector discussed with the:

licensee.during the exit meeting on June._27, .1986. These. observations are ,

neither violations nor unresolved items. These items were recommended for

licensee consideration for p'rogram improvement, but they have no specificj '

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y regulatory requirement.

a. Contamination Control - The licensee has:not implemented.an

aggressive program-to eliminate unnecessary skin contaminations. (See

paragraph'll for details).

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b. ALARA - Drainage from liquid systems is not effectively controlled.

(See paragraph 7 for details).

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4. Advanced Planning and Preparatio'ns

The NRC inspector reviewed preparations for the Unit 2l refueling outage

'(2R5) involving auxiliary building and reactor containment-

decontamination, insulation removal,. p~rimary side steam generator

inspection,' secondary side steam generator sludge removal and inspections,

and: pressurizer piping modifications. .The NRC inspector held discussions

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with outage coordinators and HP. personnel working as liaisons in'the ANO-

Planning and Scheduling Section of the Work Control Center (WCC). The NRC

inspector noted that.the HP personnel-in the WCC were able to developr. .

Radiation Work Permits fo'r HP supervisor review in a' timely manner du'e to' ' '

the WCC interface and a newly? implemented computerized radiation

protection records management system. : Records of mockup training and.

. completed work involving the steam generators were reviewed. The NRC.

-inspector. attended-daily scheduling meetings where upcoming events.and

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current problems were discussed. The.NRC' inspector noted that all"

' departments. associated with the outage were represented.

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._No violations' or deviations were identified.

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' 5. Staffing, Qualifications, and Training

Staffing, pers'onnel qualifications, and training programs provided to

workers _were inspected for compliance with the requirements of Unit 2

Technical Specification (TS) 6.3 and 6.4, Chapter 13 of the Updated Safety

Analysis Report (USAR); and the recommendations of RG 1.8 and industry-

standard ANSI N18.1-1971.

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The NRC-inspector determined that the licensee had~ hired approximately 60

additional contractor health physics technicians for the outage.

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-Approximately'36 of'these ' temporary technicians satisfied ANSI N18.1-1971

, criteria for senior'HP. technicians. The.NRCLinspector.-reviewed selected ~

T temporary employee. resumes. Assignment of personnel' appeared to be-

consistent with_their. individual qualifications. ;The NRC inspector.noted. x

' ' , thatLpersonal' resumes of personnel hired for positions"in1the..HP group had. . -

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-been individually reviewed by HP supervisors,-and personnel.were' tested-

Land trained per ANO procedures prior to, work assignment. The NRC:

, inspector verified that? training programs' for other contractor workers'

(maintenance,' operations, and technical specialities) conformed to the

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requirements of 10 CFR Part 19.12 and ANSI N18.1.-1971. Full mockup. 1

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training, including required radiological controls,' was provided- '

individuals involved 'in the primary side inspecti.on of. the steam

. generators. The NRC N oector noted remedial training was provided to

contractor 1HP personnel u.iindicated weaknesses in_ the qualification-

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s < ~~ The 'NRClinspectors held . discussions with, several temporary workers

% (firewatchers,and maintenance support) who were. working in radiologically

'Y ' controlle'd areas (RCA)!concerning their. knowledge 'about radiation exposure

" 7 yeand ALARA.t These discushions revealed that, even though workers had ~

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training, they could not readily recall the specific topics

overed...in t.he t,rainingr

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The NRC inspectbr reviewed the ALARA program to determine the degree.of.

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licensee observance of the guidanc'e in 10 CFR Part 20.1(c), and adherence-

to ANO procedures.

The. licensee had established radiation ~ exposure, personnel contamination

incident, and radioactive waste goals for the outacc. The licensee's

-preplanning, use of shielding and decontamination to reduce both external

and internal exposures was reviewed. Preplanned decontamination of.

selected reactor containment areas and the use of engineered filtered-

ventilation systems was initiated early in the outage;to reduce the need

for respiratory protection equipment and multiple layers of protective

clothing. The NRC inspector noted the frequent use of temporary shielding-

to reduce general area radiation levels. The licensee evaluates piping

system stresses due to shielding loading.

During outage planning meetings held on June 23 and 24, 1986, the NRC'

inspector noted that personnel from the HP group addressed problems

involving the uncontrolled draining of reactor plant systems on floor

surfaces within the Unit 2 reactor containment and the added exposure

being incurred by decontamination personnel in cleaning up these wetted '

areas. Also, the NRC inspector held discussions with HP group supervision '

on the authority vested in contractor HP technicians. Licensee

representatives informed the NRC inspactor that contractor HP technicians

had the same authority as ANO HP technicians when it came to enforcing ANO

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radiation' protection program and 10 CFR Part 20 requirements. 'During-

, inspections'of the Unit 2 reactor containment on June 26, 1986, the NRC

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inspector noted the following:

. Uncontrolled draining of a feedwater line from approximately the

361 foot level.(north side) down onto the basement level of the

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' containment. jThis draining causes flooding of the basement area ~

(25 percent) and at least one posted surface contamination area.

-When' questioned about the flooding, a contractor HP technician-

working in the--containment replied that "that's the'way operations

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does it." The shift supervisor, when questioned by the HP

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,  ! Superintendent (shortly after the start of the draining), replied

that""he'would see-if they could get a hose attached to the pipe."

Five workers were laying and sitting on the deck grating adjacent'to

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the westiend of the refueling cavity on the 404 foot level of the

containment. The five persons consisted of one ANO supervisor and

fodr-contractor personnel. The refueling cavity had been flooded and

the nearby reactor head was on its shielded stand. Dose rates in-the

area were from 3-20. mrem per hour. When questioned as to why they

were lounging in the area, the ANO supervisor. replied that they were ,

awaiting the arrival of a mechanic to repair the polar crane and had

been waiting approximately 45 minutes. The NRC inspector noted that

two additional persons were also in the area for rigging / signaling

and crane operation. A contractor HP technician working in

containment expressed to the NRC inspector his desire to have the

workers leave the area, but felt that he did-not have the authority

to make them leave. The ANO supervisor explain'ed to the NRC

inspector that they (four of the five personnel) had to remain in the

area since the crane's hook was over the reactor vessel. When the

NRC inspector questioned the five workers' about ALARA objectives only-

the ANO supervisor and one of the contractors was able to discuss

ALARA concepts. The NRC inspector had previously noted that several

other nearby areas in the reactor containment had ambient radiation

levels below 1 mrem per hour.

The NRC inspector discussed the aforementioned observations with the HP:

Superintendent upon exiting the reactor containment. The HP

Superintendent expressed dismay that the contractor HP technicians might

be reluctant to enforce ANO requirements on ANO employees and other

contractors and assured the NRC, inspector that he would ensure that the

contractor HP and ANO technicians were informed of their authority to

enforce ANO procedures. The above noted occurrences are indicative of an

apparent breakdown in management control over implementation of an

effective ALARA program and support for the ALARA program by the ANO

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operations and maintenance departments. This concern was discussed with

the licensee by telephone on July 7 and 8, 1986. The licensee contended

that ALARA practices were implemented by the workers awaiting the crane

repair in that they moved from the reactor vessel work stand to the lower

radiation area where they were observed by the NRC inspector. The

licensee could not provide sufficient justification for the number of

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. persons loitering' and. laying about the .a'rea or the poor exa le.of

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~ exposure. reduc _ tion. techniques demonstrated by the ANO supervisor in char'ge ,

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No fvio1ations or' deviations were identified. '

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8 .- External' Radiatio ~nExposure-Contvol

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Theklicensee'sexternalradiation_exposureprogramwasLinspect'edto. .,

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determine compliance with the commitments contained =in the Chapter-12 of

Lthe Unit 2 USAR; the. requirements.of Unit 2 TS 6.11 and 6.13; 10 CFR

Parts 19.12, 19.13, and 20.101',- 20.102, 20.104, 20.109,-20.202, 20.203,

20.205,'20.206, 20.405,~20.407,~20.408, and 20.409; and the1 +

recommendations of NRC Inspection and Enforcement (I&E) Information

Notices 86-24, 85-87, 85-60, 85-42, 84-61, 84-60, and 84-59; NRC RGs 8.26 -

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--8.4, 8.7, 8.8, 8.13, 8.14, Land 8.28;_and industry standards

i 1 ANSI N13.11-1983, N13.5-1972, and N13.27-1981.

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The-NRC inspector' inspected personnel exposure records,' authorizations to

exceed ANO administrative exposure limits, access controls over high

L ' radiation areas, dose rate evaluations.of steam generator areas, steam

generator. entry stay time logs and special' dosimetry processing records,

records on the use and placement of multiple-whole body.and extremity:

dosimetry, f. kin exposure evaluations, lost dosimetry evaluations, and

personnel-exposure tracking. The NRC inspector discussed with the

licensee the acceptability of personnel exposure records,for contractor.

personnel'from the Federal Republic of Germany and the methods to use in

verifying personnel exposures.

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No' violation's or deviations were identified. -

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Internal + Radiation Exposure Control

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.The licensee's program for'. control of-internal expcsures was inspected to- ~

cdetermine complianceiwith the requirements of 10 CFR Part 20.103, and the

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t recommendations of NRC RG 8.15 and NUREG-0041.

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The'NRC inspector reviewed respiratory protection equipment (RPE)

' maintenance, issuance,- field testing and use, return, and facilities:for

the decontamination and sanitizing. The NRC inspector noted that the

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' licensee had resolved the concern referenced in NRC Inspection

Report 50-313 & 368/86-16 regarding deteriorating stencils on breathing

air bottles. .The licensee was noted to have required the use of RPE for

high-risk airborne jobs, maximized the use of~~ engineered ventilation, and

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-performed prework decontamination to eliminate the use of RPE wherever

b possible. The NRC inspector discussed with licensee representatives'the

need to insure that HP technicians closely observed personnel donning RPE.

The NRC inspector noted during inspections of the reactor containment that

large groups of personnel were donning RPE (installation and snubber

removal personnel)'and that several of the personnel were using RPE for

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the first of; second time.and were unsure of the proper donning procedures.

The NRC inspector'noted that the licensee had established an airborne ~

exposure . tracking program for personnel working in various portions of > the

plant.'  ;

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No violations'or~ deviations were identified.

10. Posting,i Labeling, and Worker' Controls

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The licensee,'s" program for control of. workers and posting and labeling of

radioactivelmaterial and areas was inspected for compliance with the

requirements of. Unit 2 TS 6.13.1 and 6.13.2, 10 CFR Parts.19.12,i20.203,6

> 20'205,

.- 20.207,'and 20.301. The NRC inspector also reviewed the < '

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licensee's actions taken in regard to NRC I&E Bulletin 78-03, " Radiation ,

Levels'from Fuel Element Transfer Tubes."

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~The NRC inspector-reviewed the licensee's posting of radiation areas, high

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radiation' areas, the positive access controls established over very high i

radiation areas within the reactor containment and auxiliary building,

airborne radioactivity areas, packaged waste, and radioactive material

storage areas.

The NRC inspector noted that the HP technicians manning the control point

within Unit 2's containment did not have ready access to the applicable

RWPs. After discussions with the licensee, action was taken to provide

the control' point personnel with copies of all RWPs applicable to the work

within the containment.

The NRC inspector also inspected the licensee's actions taken in-response

to NRC I&E Bulletin 78-08. The licensee responded to the NRC via ANO

Letter (2-088-8), dated August 14, 1978, that a review was conducted of

the Units 1 and 2 fuel transfer tubes and that exposed tube areas were

identified. The licensee further stated that "per the subject bulletin,

we will post and assure positive control ofiaccess to entryways into this

area." On June 24, 1986, the NRC inspector ~ determined during an

inspection of the Unit 2 containment side fuel transfer tube area that

grating (bolted down) providing access to the fuel transfer tube area was

not posted to indicate the potential for very high-radiation levels below

the grating. The above noted conditions appear to deviate from

commitments made to the NRC in regard to compliance with the requirements

of I&E Bulletin 78-08 (368/8617-02). The NRC inspector could not inspect

Unit 1 areas within the reactor containment, due to the reactor being at

power. ;This deviation was discussed further with licensee personnel in

telephone conversations on July 7 and 8, 1986.

No violations were identified. ,

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11.1 Controlt of Radioactive Materials-(RAM) and Contamination, and

o Radiological Monitoring

'The licensee's programs:for the control of RAM and contamination, and for-

radiologicalisurveys and monitoringLwere reviewed for compliance with:the

.... ' commitments. contained in. the Unit' 2 TS 3/4.7.9, 6.11, and 6.13; 10 CFR

st _Part 19.12,'20.4, 20.5, 20.201,.20.203, 20.205, 20.207, 20.301,-20.401,

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-The NRC inspector: inspected the licensee's radiological survey program

' involving work areas, storage areas, change rooms, lunch and meeting' _ - .

rooms, contractor. service facilities, and radiological' control points for

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the surveying and release of materials and personnel. The NRC inspector. -

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also. reviewed the control exercised over' radioactive materials transferred

to-onsite vendor facilities forftesting and maintenance. _ Temporary work

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areas established out' side of the > reactor auxiliary buildings and '

containments were' inspected. -Logs of material removed from radiologically

controlled areas were reviewed.

The NRC inspector reviewed and discussed with licensee _ personnel the: "

current status of personnel skin contamination incidents'that have

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occurred since the start of the outage. :The licensee'had set a goal-of-no

more than'130 skin contamination incidents during the outage. The_ Unit-2

outage wasistarted on or about June 13, 1986. 'As of: June 23, 1986,

approximately 302 skin contaminationsincidents had been ' reported and by1

June 26, 1986, the-number had increased to'approximately'50, with only-

?approximately 30' percent of work in the outage completed. The-licensee 4

determined _that a majority _of the skin contaminations had occurred during

insulation removal. -The working conditions for insult. tion removal-

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involved high ambient temperatures and high-levels'of readily removable

surface contamination. Decontamination of the areas was not practical due

to the certain r.econtaminatien of,the areas during insulation removal.

Due to the heat' stress on personnel working on the insulation removal',

plastic outer clothing was not used. Double-sets'of cloth protective

clothing-(PC)..were used for the work. Personnel perspiration caused

significant' transfer of co_ntaminants through the cloth PC's resulting.in

many skin contamination incidents. Several other observations on causes-

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of certain skin' contamination incidents were noted to the licensee by the

NRC inspectoi. These observations were based 01 discussions with

. personnel involved in skin contamination incidents, HP technicians,

' observations of radiological work practices of workers, and reviews of

incident reports on personnel skin contaminations. A chief contributor of

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theseLincidents=was the licensee's reliance on decontamination efforts.to

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, reduceithe~overall' risk of personnel contamination within areas when there

still existed high levels of imbedded radioactivity on walls and component

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surfass'. . The NRC inspector noted that the licensee was fully aware of

> - tthe absorbent properties of the cloth PC's when wetted, but did not take

actionf to' implement, mandatory use of impervious outer PC's when working in

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1'.'high_lyicontaminated areas, and the work operations would reasonably be

' expected to cause workers' extremities to come into contact with the

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highly contaminated surfaces for extended periods of' time. The NRC

inspector. discussed the.following methods that could be considered in

order to reduce skin contamination incidents:

Enforcement of good radiological work practices regarding wearing and

use of PC's.

Use of double rubber gloves and the routine replacement of the outer -

pair to. minimize the transfer of radioactivity from one area to

a lanother,:especially to, the worker during RPE and PC removal.

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Use'of plastic outer PC's in conjunction with personnel cooling units

,for. work operations involving potential- heat stress problems.

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Providing' work'ers with plastic / rubber arm and leg / knee sleeves.

Evaluate the use o'f breathing and cooling air supplied suits for

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' physically demanding work in areas of high temperatures.

Even[though thel personnel skin contamination incidents did not result in

any significant skin exposures, the NRC inspector noted that these

incidents indicated weaknesses with the radiation protection program.

AN0 TS 6.11 (Unit-2) requires, in part, 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 personnel radiation exposure." AN0

Procedure 1622.008, " Marking and Handling of Radioactive Material and

Equipment," Paragraph 6.8.2.C.1.b requires that radioactive material

stored outside of the controlled access area be accounted for in

accordance with the tagging and accountability inscructions of the

procedure. AN0 Procedure 1612.003, " Radiological Work Permits,"

Paragraph 5.6 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, . . ." RWP 860193,

Revision 2, "Wyle to Test, Transport Dispose of in Test Trailer," provides

instructions on the transfer of equipment snubbers from within the Unit'2

reactor containment via the equipment hatch to a test trailer located near

the maintenance building, and the storage and testing of the' snubbers at

the trailer. The special instructions of the RWP require that the

snubbers be wrapped prior to transfer to the trailer and that the loose

surface contamination levels be reduced to as near 1,000 dpm/100cm2 as

possible. RWP 860131, Revision 0, "HP Operations at the U2 Equipment

Hatch," requires that certain tasks be performed concerning the removal of

materials from the Unit 2 containment via the containment equipment hatch. .

lnis RWP requires that smear and radiation surveys be performed and

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documented (on ANO form 1622.001C), and all radioactive materials must be

tagged with a RAM tag showing radiation and contamination levels of the

item for all materials removed via the equipment hatch. On June 26, 1986,

the NRC inspector observed the work activities of an HP contractor

technician assigned to cover the removal of equipment snubbers from Unit 2

to~the Wyle Laboratory onsite test trailer.

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During the removal of the

unwrapped snubbers from the coritainment equipment hatch, the'NRC inspector

inquired as to the levels of loose surface ~ contamination on the snubbers

being loaded into a crane; rigged skip box. The HP technician stated that

the snubbers were less than 10,000 dpm/100 cm2 since this was the lowest

level detectable within the Unit 2 containment due to background radiation

levels. The HP technician only surveyed the snubbers for general area

beta / gamma radiation (within several inches) dose rate levels. When it

- became evident that the HP technician was not going to wrap or bag the

snubbers, the NRC inspector questioned methods to be employed to prevent

the spread of loose contamination during snubber transfers. The HP

technician had workers cover the snubbers with a plastic sheet. The

stiubbers were subsequently transferred to the Wyle-trailer. However, the

' unwrapped snubbers were not tagged or labeled to indicate their

radiological status nor were they accounted for in accordance with.the. '

requirements of Procedure 1622.008. As of June ~27, 1986,- the NRCl

inspector could not locate or be provided documentation on form 1622.001C

for the snubber release via the equipment hatch. The. failure to properly

review and comply with RWP requirements and other station procedures are.

additional examples of the violation (368/8617-01)' discussed in ,

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Paragraph 7 of this report concerning failure to follow procedures.

No deviations were identified.

12. Independent Confirmatory Measurements *

The NRC inspector performed independent radiation surveys throughout the -

licensee's facility, verified posting, and compared dose rates obtained

with licensee's survey results. The licensee had implemented actions to

update existing radiation hot spot labeling (greater than 100 mrem per

hour and greater than 4 times general area levels) within Unit 2 reactor

containment and auxiliary building.

No violations or deviations were identified.

13. Exit Interview

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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 June 27, 1986. The NRC inspector

summarized the inspection findings.