ML20236B578
| ML20236B578 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/21/1987 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236B544 | List: |
| References | |
| 50-313-87-25, 50-368-87-25, IEIN-86-023, IEIN-86-23, NUDOCS 8710260246 | |
| Download: ML20236B578 (8) | |
See also: IR 05000313/1987025
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-313/87-25
Licenses:
50-368/87-25
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Dockets: .50-313
50-368
Licensee:
Arkansas Power and Light Company (AP&L)
P. O. Box 551
Little Rock, Arkansas
72203
Facility Name:
Inspection At:
AN0 Site, Russellville, Pope County, Arkansas
Inspection Conducted:
September 14-18, 1987
Inspector:
MlhMV/
[O/8//87
H. Chaney, Radiation $ppcialist, Facilities
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Radiological Protection Section
Approved:
8 @ Mb/1
/6[8//87
Date '
B.Murray, Chief,FacgtiesRadiological
Protection Section
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Inspection Summary
Inspection Conducted September 14-18, 1987 (Reports 50-313/87-25;
50-368/87-25)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiation
protection program including external occupational exposure control and
dosimetry, internal exposure control and assessment, control of radioactive
materials and contamination, surveys and monitoring, and facilities and
equipment.
Results: Within the areas inspected one violation (failure to survey, see
paragraph 8) was identified.
No deviations were identified.
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DETAILS
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1.
Persons Contacted
- J. M. Levine, Executive Director, AN0' Site Operations
- E. C. Ewing, General Manager, Plant Support
- L. W. Humphrey, General Manager, Nuclear Quality
- T. C. Baker, Technical Support Manager
- E. E. Bickel, Health Physics (HP) Superintendent
- R. Carroll', Corporate HP
- D. Howard, Special Projects Manager
- D. B. Lomax, Plant Licensing Super.'sor
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- P. Michalk, Plant Licensing Engineec
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- H. Greene, Quality Assurance (QA) Superintendent
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- D. Graham, Quality Control Engineering Supervisor
B. L. Bata, QA Engineer
'W. L. Hada, HP Supervisor
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B. C. Burchard, HP Supervisor
R. Green, Dosimetry Supervisor
R. D. Deal, Dosimetry Technician
L. E. Qualls, Dosimetry Technician
R. M. Tipton, Dosimetry Clerk
J. J. Garren, Dosimetry Technician
B. R. Creech, Dosimetry Technician
- D. W. Akins, Radioactive Waste (Radwaste) Supervisor
H. N.. Bishop, Assistant Radwaste Supervisor
R. Davis, HP and Radwaste Trainer
R. Gillespie, Technical Analyst Superintendent
Di R. Grace, HP Technician
T. Pugh, Lead Trainer
T. Rolniak, Lead Trainer
M. R, McIntosh, HP Supervisor
T.
T. Smith, HP Supervisor
Others
- C..C. Harbuck, NRC Resident Inspector
- D. R. Hunter,-Chief, Reactor Projects Section B
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A. T. Murray,' Dosimetry Technician, Contract Technician
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R. H. Drake, Technician Supervisor, Contract HP
M. Davis, Radiographer, US Testing
R. Jackson, Radiographer, US Testing
- Denotes those present at the exit interview on September 18, 1987.
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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-interview on September 18, 1987.
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 state that the observations would be reviewed.
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Waste Segregation - The licensee's co'ntamination control progratt
a.
involves the survey of large^ quantities of materials removeu from
radiologically controlled areas which indicates that the licensee has
not implemented a proper program to restrict the amount of materials
allowed to enter radiologically controlled areas.
b.
Personnel Dosimetry Program - The quality control program for the
.thermoluminescent dosimeter (TLD) reader does not include response
tests.in the 50 to 100 mrem range.
.c.
Hot Radioactive Particles - The licensee had not formally documented
their program concerning assessing potential sources, indoctrinating
personnel, and evaluating personnel contamination monitoring
instrumentation for the detection of hot particles.
3.
Open Items Identified During This Inspection
An open item is a matter that requires further review and evaluation by the
NRC inspector.
Open items are used to document, track, and ensure adequate
followup on matter of concern to the NRC inspector.
The following open
items were identified:
Open Item
Title
See Paragraph
313/8725-02 &
Dosimetry Technician Training
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368/8725-02
313/8725-03 &
Long Term Radiation Work Permits
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368/8725-03
4.
Program Areas Inspected
The following program areas were inspected.
These program areas and
inspection procedures are identified in NRC Manual Chapter 2500.
Unless
otherwise noted, the inspection was completed and revealed no violations,
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deviations, unresolved items, or open items.
Notations after a specific
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inspection item are used to identify the following:
I = item not inspected
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or only partially inspected; V = violation; D = deviation; V = unresolved
item; and 0 = open item.
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Procedures
Inspection Requirements
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83723
Training and Qualifications (Radiation Protection)
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02.01 - Adequacy of Training - 0, (see paragraph 5)
02.02 - Employee Knowledge
02.03 - Transportation /Radwaste Training - I
02.04 - Qualification Requirements - 0, (see
paragraph 5)
02.05 - New Employees
02.06 - INPO Accreditation
02.07 - Audits and Appraisals
02.08 - Training Not Covered by INP0-0, see
paragraph 5
83524
External Occupational Exposure Control and Personal
Dosimetry
-02.01 - Physical Controls
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02.02 - Administrative Controls
02.03 - Personal Dosimetry
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83724
External Occupational Exposure Control and Personal
Dosimetry
02.01 - Audits and Appraisals
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02.02 - Changes
02.03 - Planning and Preparation for Outages
02.04 - Personal Dosimetry
02.05 - Administrative Controls - 0, (see paragraph 7)
02.06 - Records, Reports, and Notifications.
83525
_ Internal Exposure Control and Assessment
02.01 - Administrative Controls
02.02 - Engineering Controls
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02.03 - Respiratory Protection Equipment
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02.04 - Air Sampling
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02.05 - Bioassays
83725
Internal Exposure Control and Assessment
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02.01 -' Audits and Appraisals
02.02 - Changes
02.03 - Planning and Preparation for Outages
02.04 - Assessing Intakes of Radioactive Materials
02.05 - Engineering and Administrative Controls
02.06 - Respiratory Protection Equipment
02.07 - Records, Reports, and Notifications
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83526
Control of Radioactive Materials and Contamination,
Surveys, and Monitoring
02.01 - Area Radiation and Airborne Radioactivity
Monitors
02.02 - Portable Survey, Sampling, and Contamination
Monitoring Instruments
02.03 - Protective Clothing and Equipment
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02.04 - Radioactive Material and Contamination Control
02.05 - In-Plant Surveys.and Monitoring
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83726
Control c/ Radioactive Materials and Contamination,
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Surveys, ai d Monitoring
02.01 - Audits and Appraisals
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02.02 - Changes
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02.03 - Surveys and Monitoring .
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02.04 - Radioactive Materials and contamination Controls
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- V, see paragraph 8
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83527
Facilities and Equipment
02.01 - Facilities
02.02 - Equipment
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83727
Facilities and Equipment
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02.01 - Facility Changes
5.
Personnel Dosimetry Program
The'NRC inspector conducted a review of the licensee's personnel dosimetry
program.
The licensee recently changed (January 1987) dosimetry equipment /
system vendor and is in the process of having the new system accredited
under the National Voluntary Laboratory Accreditation Program (NVLAP).
The
licensee is using a state-of-the-art, computerized, multiple-element TLD
system.
The TLD system is supplemented by the use of self reading pocket
dosimeters (SRD) between the monthly TLD processing periods.
Based on the
licensee's performance in a independent laboratory cross check program,
their appears to be no problem in the licensee's system meeting NVLAP
accreditation standards.
The TLD badge is a four element Panasonic Model 802 AS.
Two elements are
natural lithium (Li-6) borate granules and two are calcium (Ca) sulfate
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granules of 15 milligrams per square centimeter (mg/cm ) nominal thickness.
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The filtration over the elements, including that provided by the hanger, is
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as follows:
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ELEMENT
' FILTRATION (mg/cm )
2
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28 (mylar)
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300 (mylar, plastic)
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300 (mylar, plastic)
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1000 (lead, plastic)
The licensee's badge'(TLD and Holder) approximates the density of tissue.
The badge has been calibrated to provide dose equivalents for gamma, beta,
and neutron radiations.
The licensee also uses this TLD for extremity-
monitoring.
The licensee's inhouse TLD calibration program system
consists of exposure to cesium-137 with the TLDs placed on a plexiglass
phantom.
Studies of the TLD's response to low energy beta radiation have
been accomplished.
The NRC inspector reviewed experience and training records of personnel
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assigned to the dosimetry program.
The dosimetry supervisor and the
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dosimetry technicians have participated in specialized training provided by
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the TLD vendor and the University of Michigan.
However,'the licensee had
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not completed development of a formal training program for the position of
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dosimetry technician.
This is considered an open item pending the
development and implementation of a training and qualification program for
the dosimetry technician position.
(313/8725-02;368/8725-02)
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No violations or deviations were identified.
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6.
Skin Contamination / Hot Particle Dose Assessment-
The NRC inspector reviewed the licensee's program for the prevention and
assessment of skin dose from radioactive contamination involving hot
particles. 'The licensee's program includes detailed surveys of plant areas
with special large area high retention wipes and the use of high
sensitivity (Eberline PCM-1) personnel monitors for monitoring personnel
exiting radiologically controlled areas.
The licensee's laundry
(Interstate Nuclear Services) utilizes state-of-the-art high sensitivity
laundry monitors for surveying laundered protective clothing.
The licensee's hot particle program was developed using several industry
documents and NRC Inspection and Enforcement Information Notice (IEN) 86-23.
The licensee's assessment program included the following features:
Procedures have been established for assessing personnel skin dose.
Contamination is measured primarily with a beta / gamma frisking probe
(Eberline HP 210 equivalent) of approximately 15.5 cm2 detection area.
The resulting readings (counts per minute) are converted to disintegra-
tions per minute (10 percent efficiency), and averaged over on the size
of the contaminated area.
An area of 1 cm2 contamination is assumed
unless more definitive information is known about the contaminated
area.
The licensee had not included specific instructions for the use
of portable radiation detection instruments other than the HP 210 probe.
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The assessment only evaluates the beta component; gamma exposure is
regard as providing only a small dose contribution.
The licensee will. utilize the skin dose assessment Computer Code
VARSKIN (HUREG/CR-4418).
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An attempt is made to find and retain the hot particle for specific
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radionuclides identification.
The licensee plans to perform detailed contamination surveys during
major component disassembly and fuel shuffling.
The licensee will
obtain samples from inside major components for determination of
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fission product contamination plate out.
-The licensee's skin dose assessment and hot particle controls appears to
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incorporate the recommendations of IEN 86-23.
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No violations or' deviations were identified.
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7.
Radiation Work Permits (RWP)
The NRC. inspector determined during a review of the RWP program that the
licensee was allowing certain radiological work to be controlled by the
issuance of a long term " general" RWP.
The " general" RWP is intended for
radiological work activities that involved relatively stable radiological
conditions.
The NRC inspector reviewed a specific job involving the liquid
radwaste processing filter system that has a high potential for a
radiological spills and changing high radiation levels.
This review
revealed that the radiological conditions associated with the filter system
were not in_ agreement with guidance provided in Procedure 1612.03, "RWP".
Based on the results of these reviews, the licensee terminated RWPs (870076,
870077, and 870078) associated with this operation until the job was
further reviewed and a new set of " specific" RWPs were issued.
This is considered an open item pending licensee review of all " general"
RWPs to determine agreement the guidelines contained in Procedure 1612.03.
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-(313/8725-03;368/8725-03);
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No violations or deviations were identified.
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-8.
. Radioactive Material Control
During the performance of independent surveys by the NRC inspector and
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-licensee personnel, hand tools with various amounts of radioactivity were
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-found in an uncontrolled area outside of the licensee's radiologically
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controlled areas.
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10 CFR Part 20.201(b) requires that licensee 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
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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.
Furthermore,.TSs 6.10.and 6.11 for AN0 Units 1 & 2, respectively, require
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that procedures for personnel radiation protection shall be adhered to for
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all operations' involving personnel radiation exposure.
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Licensee Procedures'1622.001, " Radiological Surveys and Documentation;"
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1622.008,." Marking and Handling of Radioactive Material and Equipment;"
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1622.017,'" Operation of a Control Point;" and 1000.031, " Radiation
Protection Manual," require that material be considered as radioactive if
during a direct frisk / survey with an Eberline RM14 count rate meter using
an HP 210 probe (RM 14/HP 210) the material exhibits activity of 100 count
per minute (cpm) above background (approximately 1000 disintegrations per
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minute using the licensee's conversion factor of 10 for this beta / gamma
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detector).
Material must be controlled, labeled, and/or marked as
radioactive material when it exceeds the aforementioned limit.
The NRC inspector found one hand tool (side-cutter pliers) with
radioactivity greater than 1000 dpm above background (approximately 500 to
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600 cpm in the clean tool room) and the licensee found several more tools
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with fixed radioactivity in the range of 3000 to 30,000 dpm (approximately
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300 to 3000 cpm).
The licensee conducted a complete survey of the clean
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tool room an removed all tools showing greater than 1000 dpm.
The surface
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of all the tools appeared to have been sandblasted.
The licensee stated
that the tools were items which had been previously liquid-abrasively
cleaned / decontaminated and recently released from radiologically control by
HP personnel following a smear.and direct frisk.
The failure to properly
survey material per station procedures is an apparent violation of TSs 6.10
and 6.11 of ANO Units 1 & 2 TSs, respectively, (313/8725-01;368/8725-01).
The NRC inspector discussed with licensee representatives, at the exit
interview, the need to ensure that survey methods and instrumentation are
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adequate to prevent the release of radioactive material into uncontrolled
areas.
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No deviations were identified.
9.
Exit Interview
The NRC inspector met with the NRC resident inspector and licensee
-representatives denoted in paragraph 1 on September 18, 1987, and
summarized the scope and findings of the inspection as presented in this
report.
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