ML20236B578

Insp Repts 50-313/87-25 & 50-368/87-25 on 870914-18. Violation Noted.No Deviations Noted.Major Areas Inspected: Licensee Radiation Protection Program,Including External Occupational Exposure Control & Dosimetry

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: ML20236B541 ML20236B559 ML20236B578
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

NRC Inspection Report: 50-313/87-25 Licenses: DPR-51

50-368/87-25 NPF-6

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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: Arkansas Nuclear One (ANO)

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

Inspection Conducted: September 14-18, 1987

Inspector: MlhMV/ [O/8//87

H. Chaney, Radiation $ppcialist, Facilities D' ate '

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Radiological Protection Section

Approved: 8 @ Mb/1 /6[8//87

Date '

B.Murray, Chief,FacgtiesRadiological

Protection Section i

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

AP&L

• 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 ,

• P. Michalk, Plant Licensing Engineec l

• 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 >

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. W.' Nickels, HP Supervisor

T. Smith, HP Supervisor

Others

• C..C. Harbuck, NRC Resident Inspector

• D. R. Hunter,-Chief, Reactor Projects Section B .

A. T. Murray,' Dosimetry Technician, Contract Technician l

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 I

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. ,

a. Waste Segregation - The licensee's co'ntamination control progratt

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 5

368/8725-02

313/8725-03 & Long Term Radiation Work Permits 7

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, l

deviations, unresolved items, or open items. Notations after a specific i

inspection item are used to identify the following: I = item not inspected j

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 ,

02.02 - Administrative Controls

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02.03 - Personal Dosimetry  ;

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83724 External Occupational Exposure Control and Personal

Dosimetry

02.01 - Audits and Appraisals I

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 i

02.03 - Respiratory Protection Equipment J

02.04 - Air Sampling 1

02.05 - Bioassays

83725 Internal Exposure Control and Assessment 1

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 4

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,

Surveys, ai d Monitoring f

02.01 - Audits and Appraisals j

02.02 - Changes ]

02.03 - Surveys and Monitoring . .

02.04 - Radioactive Materials and contamination Controls ]

,; - V, see paragraph 8

83527 Facilities and Equipment

02.01 - Facilities

02.02 - Equipment l

83727 Facilities and Equipment I

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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

granules of 15 milligrams per square centimeter (mg/cm2) nominal thickness.

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The filtration over the elements, including that provided by the hanger, is

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ELEMENT ' FILTRATION (mg/cm2 )

1 28 (mylar)

2 300 (mylar, plastic)

3 300 (mylar, plastic)

4 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 ,

assigned to the dosimetry program. The dosimetry supervisor and the

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dosimetry technicians have participated in specialized training provided by j

the TLD vendor and the University of Michigan. However,'the licensee had j

not completed development of a formal training program for the position of j

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.

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). j

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 3

fission product contamination plate out.

-The licensee's skin dose assessment and hot particle controls appears to 'l

incorporate the recommendations of IEN 86-23.

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No violations or' deviations were identified.  !

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.

-(313/8725-03;368/8725-03);

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No violations or deviations were identified. ]

-8. . Radioactive Material Control

During the performance of independent surveys by the NRC inspector and l

-licensee personnel, hand tools with various amounts of radioactivity were l

-found in an uncontrolled area outside of the licensee's radiologically 1

controlled areas. .

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 i

that procedures for personnel radiation protection shall be adhered to for i

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;"

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 j

minute using the licensee's conversion factor of 10 for this beta / gamma 1

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  !

with fixed radioactivity in the range of 3000 to 30,000 dpm (approximately j

300 to 3000 cpm). The licensee conducted a complete survey of the clean i

tool room an removed all tools showing greater than 1000 dpm. The surface

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 i

adequate to prevent the release of radioactive material into uncontrolled

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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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