IR 05000313/1985017

Insp Repts 50-313/85-17 & 50-368/85-18 on 850617-28.No Violation or Deviation Noted.Major Areas Inspected: Radiation Protection Activities,Including Organization, Training & Qualifications & External Exposure Control

ML20134N324
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/20/1985
From:	Baer R, Martin L, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134N319	List: IR 05000313/1985017 ML20134N316
References
50-313-85-17, 50-368-85-18, NUDOCS 8509050092
Download: ML20134N324 (14)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC-Inspection Report: 50-313/85-17 License: DPR-51 50-368/85-18 NPF-6 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 (ANO) Units 1 and 2 Inspection At: ANO Site, Russellville, Arkansas Inspection Conducted: June 17-28, 1985 Inspector: 8M9/Bs R. E. Baer, Radiation Specialist Date .

Facilities Radiological Protection Section Approved:

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8 8 84 Date

/ p . Murray, Chief, Facilities Radiological

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Protection Section

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s LT E.~ Martin, Ch f, Reactor Project Section 8

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Inspection Summary Inspection Conducted June 17-28, 1985 (Report 50-313/85-17; 50-368/85-18)

Area's Inspected: Routine, unannounced inspection of the licensee's' radiation protection activities during normal plant operations including: licensee action on previously identified violations and open items; radiation protection organization; training and qualifications; external. exposure control; internal ~

exposure control; control of radioactive material and contamination, surveys, and monitoring; facilities and equipment; ALARA; and audits The inspection involved 83 inspector-hours onsite by one NRC inspecto Results: Within tre nine areas inspected, no violations or deviations were identifie PDR ADOCK 05000313 G PDR

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. DETAILS Persons Contacted AP&L J. M. Levine, General Manager

• T. H. Cogburn, General Manager Nuclear Services D. W. Akins, Radwaste Supervisor B. A. Baker, Operations Manager

• T. C. Baker, Technical Analysis Superintendent B. L. Bata, Quality Assurance (QA) Engineer E. E. Bickel, Health Physics (HP) Specialist

• J. Bolanis, HP Superintendent B. C. Burchard, HP Supervisor

• P. L. Campbell, Plant Licensing Engineer F. H. Chilcoat, Instrumentation and Control Technician J. D. Deal, Trainer, HP/Radwaste

• E. C. Ewing, Engineering and Technical Support Manager R. E. Green, Dosimetry Supervisor-W. L. Hada, HP Supervisor D. L. Helm, HP Specialist, ALARA Coordinator

• D. B. Lomax, Plant Licensing Supervisor M. R. McIntosh, HP Supervisor I. Mosquito, Trainer,' General Employee Training

• M. L. Pendergrass, Acting Engineering and Technical Support Manager

• G. D. Provencher, QA Supervisor J. T. Pugh, Trainer, General Employee Training T. M. Rolniak, Lead Trainer, HP/Radwaste

• E. C. Sanders, Maintenance Manager

• L. W. Schempp, Manager Nuclear Quality Control

• J. D. Vandergrift, Training Superintendent D. J. Wagner, Assistant HP Superintendent Others

• P. H. Harrell, Resident Reactor Inspector,~USNRC J. D. Buchanan, Operating Reactor Programs Branch, USNRC

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The NRC inspector also interviewed several other licensee employees including HP, administrative, operations, security, and maintenance personne !

• Denotes those present at the exit intervie ~1

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~ Licensee Action on~ Previous Inspection Findings (Closed)OpenIteml(368/8237-02): ALARA Program' Weakness - Involved the lack of corporate management review of. quarterly ALARA performances / improvements; not having a quarterly ALARA report issued from the plant; not revising employee training to resolve identified problems

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with personnel contamination incidents; not revising the Personnel Con-

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tamination Record Form 1622.010A to provide for additional information to evaluate the' basic cause of the incident; and not'providing more emphasi ~

to be directed by the HP group toward contamination control practice The-licensee had incorporated changes to Procedure 1000.33 "ANO ALARA

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Manual," which'provides-for quarterly performance reports. These quarterly reports are sent to corporate management. Radiation worker training had been revised to include a practical-factors segment where workers demonstrate their ability to properly suit up and remove con-taminated protective equipment and clothing. The Personnel Contamination ,

Record Form 1622.010A had been revised to include additional information

- so that a determination could be made-as to the principal cause for the

- contamination incident and such that improvements could.be directed to

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- reduce the number of incidents. This: item is consid6 red close (Closed) Open Item (313/8236-03): Breathing Zone Air Sampling'- Involhed the lack of a routine breathing zone airborne radioactivity monitoring-program; procedures for the evaluation of use of engineering controls; and

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surveillance, maintenance, and preuse testing for temporary HEPA" filter-ventilation systems. The licensee had implemented a personnel breathing-zone air sampling program by Procedure 1622.006, " Radiological Air Sam-pling Program." Section 8.2.7 of Procedure 1622.006 addresses breathing zone sampling and documentation. The use of engineering controls had been incorporated into the ALARA review performed for work packages so procedures for the use of temporary HEPA filter ventilation systems had been develope This item is considered close (Closed) Open Item (313/8313-02; 368/8313-02): Radiation Worker" Retraining - Involved the failure to include the recommendations of Regulatory Guide 8.27 in Radiation Worker training. The licensee had

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revised the training lesson plans to include the major elements listed in Regulatory Guide 8.27, Table 1. This item is considered close (Closed) Open Item (313/8409-02; 368/8409-02): Organizational Chart -

Involved the organizational chart contained in the Updated Safety Analysis Report (USAR) which was not consistent with the chart contained in the Technical Specifications (TS) for both units. The licensee had revised the organizational charts in the USAR for both units to be consistent with the TS. This item is considered closed.

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-4-(Closed) Violation (313/8409-01; 368/8409-01): Procedure Compliance TLD -

Involved the lack of quarterly TLD performance checks. The licensee had

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revised Procedure 1632.021, "TLD Calibration and Performance Certification,"

Revision 3, Change PC-1, December 27, 1984. Sections 11.2 and 11.3 were revised to provide for follow-up if.TLD's are not returned from the vendor and if the irradiation report had not been received within 30 days after submitting analysis data to the vendor. This item is considered close . Organization and Management Controls The NRC inspector reviewed the licensee's radiation protection organiza-tion for changes made since the previous radiation protection inspection; compliance with the USAR and TS requirements, and the recommendations of ANSI Standard N18.1-197 The licensee had not made any organizational change since the previous radiation protection inspection. The NRC inspector noted that all authorized positions were filled. The licensee had experienced a low rate of turnover (less than 10%) for personnel during the last yea The licensee has a group of decontamination technicians it uses to draw upon for replacement apprentice HP technician The licensee had qualified 23 of the 35 HP technicians'to ANSI standard N18.1-1971. The licensee doesn't automatically classify an individual at the end of a two or three year period as an ANSI qualified technicia The licensee's program for qualifying these technicians not only requires the necessary time involved with HP activities, but also includes completion of a qualification card which incorporates various plant related HP duties and an oral examinatio The NRC inspector reviewed those procedures listed in Table 3 which had been issued or changed since the previous radiation protection operations inspection. ,These procedures appear to satisfy the regulatory requirement they are intended fo No violations or deviations were identifie . Training and' Qualifications The NRC. inspector reviewed the qualifications and training requirements for the HP group and ANO training department instructors involved with providing radiation protection training for compliance with TS and 10 CFR Part 19.12 requirements; and the recommendations of Regulatory Guides 8.13, 8.27, and 8.29 and ANSI N18.1-197 The NRC inspector reviewed training programs, lesson plans on-the-job training records for selected individuals, personnel training evaluations, and held discussions with training staff personnel.

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-5-The NRC inspector discussed with licensee representatives the status of the Institute of Nuclear Power Operations (INPO) accreditation for the

'HP training program. The licensee stated that they were doing task development at present, but were currently behind in the INP0 implemen-tation schedule. .The licensee had contracted for two training develop-mental personnel to assist in the preparation of the training course The licensee stated that they expect to meet the commitment date of July 1986 for INP0 accreditation.

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The NRC inspector reviewed lesson plans for general employee training and

- discussed training objectives with licensee representatives to determine

, compliance with ANO training procedure 1063.07, " General Employee Training Program," Revision 4, March 14, 198 The NRC inspector reviewed lesson plans for the health physics staff training and discussed training objectives with licensee representatives

. to determine compliance with ANO training procedure 1063.14, " Health Physics Training Sequences," Revision 1, PC-3, May 7, 1985. The licensee was in the; process of upgrading the lesson plans to meet the INP0 guideline No violations or deviations were identifie . External Occupational Exposure Control The NRC inspector reviewed the licensee's external occupational exposure control and personal dosimetry program for compliance with the requirements of 10 CFR Parts 20.101(a), 20.101(b), 20.102, 20.202(a),

20.104(a) and 20.401(a); and the recommendations of Regulatory Guides 8.2, 8.3, 8.4, 8.7, 8.14, and 8.28, ANSI Standards N13.11-1983 and N13.15-198 The NRC inspector reviewed selected licensee exposure history records for 77 current and past ANO and contractor employees to verify that NRC limits were not exceede The NRC inspector discussed with licensee representatives the National Voluntary Laboratory Accreditation Program (NVLAP) for personnel dosimetry processors which had been published as a proposed rule making change to 10 CFR Part 20.202(c) with a proposed implementation date of February 1986. The licensee had previously attempted to become NVLAP certified and had passed five of the specified eight categorie The licensee's method for beta radiation exposure determination had over-estimated the actual exposure by approximately 50 percent. This_was partly due to the use of a depleted uranium calibration slab source instead of the recommended strontium-90. Other problems were identified in the method used to process the thermoluminescent dosimeter (TLD).

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-6-The licensee had ordered new equipment.for the processing of TLD's and expected to have the equipment operational in time to obtain NVLAP certification by February 198 The NRC inspector noted that Section 12.3.3 of ANO-Unit 2's USAR did not '

accurately describe the external dosimetry program presently in use at the statio This section refers to neutron film badges; but the licensee uses TLD-600 chips for neutron measurements. It should be noted that film is not an appropriate neutron personnel monitoring device where as TLD-600 is considered an acceptable method. The NRC inspector discussed with

> licensee representatives the need for the USAR to accurately describe the current personnel neutron dosimeter. The licensee stated that they would update Section 12.3.3 of the Unit 2 USA The NRC inspector verified that reports and notifications required to i

comply with 10 CFR Parts 19.13, 20.403, 20.405, 20.408 and 50.72(2) had l been prepared in a timely manne No violations or deviations were identifie . Internal Exposure Control and Assessment The NRC inspector reviewed the licensee's internal exposure control and assessment program to determine compliance with 10 CFR Part 20.103 and the

recommendations of RGs 8.7, 8.8, 8.9, 8.15, and 8.26 ANSI N13.1-1969 and l

N343-1978, and NUREG-004 The NRC inspector reviewed procedures, representative records for the air sampling program, maximum permissible concentration hourly logs, and whole body counter operational checks; and interviewed personnel to determine the effectiveness of the program. The NRC inspector determined the licensee's respiratory protection program and associated maintenance, l cleaning, and supporting air sampling program appeared adequate and met

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the requirements of 10 CFR Part 20.10 The NRC inspector noted that the licensee had increased their whole body l counting capabilities by the installation of a second whole body counte The licensee routinely performs whole body counts on individuals: (1)

prior to assigning them a TLD, (2) at yearly intervals, and (3) when the l work assignment is terminated.

, .The NRC inspector discussed other bioassay techniques with licensee i representatives. The licensee stated that there had been no instances when the health physics superintendent had deemed it necessary to collect and analyze urine and/or fecal samples. Should samples be collected they-would be sent to a national laboratory for analysi ' No violations or deviations were identified.

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-7-I ALARA The NRC . inspector reviewed the licensee's ALARA program to determine

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compliance with USAR commitments and recommendations of RGs 8.8, and 8.1 The licensee had projected a total man-rem exposure for both units of 1033

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for 1984, but was able to keep exposures down to 774 man-rem through a combination of improved tube plugging methods and reduction of core spray pipe work scope during the year. The annual ANO station goal originally projected for 710 man-rem for 1985, was reduced to 545 based on the reduction of pressurizer modification work schedule Table 1 provides a comparison of AN0's man-rem expenditure performance i when compared to the national single reactor averages for the years 1980 l through 1984. These data show that, except for 1983, ANO had been '

! consistently below national averages when normalized at a single reactor performanc Table 2 depicts the radiation exposure, man-rem expended for jobs requiring more than 5 man-rem,' during the period January 1 through May 31, 1985. The total man-rem expended at ANO during this period was

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22 No violations or deviations were identified.

Control of Radioactive Materials and Contamination, Surveys, and -

Monitoring

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The NRC inspector reviewed the implementation of the licensee's program

! for control of radioactive materials and contamination, surveys, and i' monitoring for compliance with: 10 CFR Part 20.105, 20.201, 20.203 and

, 20.401; TS; and USAR commitment I Radioactive Materials and Contamination Control The NRC inspector reviewed the licensee's radioactive material and contamination control program to aetermine compliance with 10 CFR

Part 20 and the TS. The following station procedures were reviewed

1603.007, " Control of Radioactive Material," Revision 7, October 15, 198 .009, " Radioactive Spills," Revision 0, October 18, 198 ,

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l 1622.008, " Marking and Handling of Radioactive Materials and Equip-ment," Revision 6, May 9, 1985.

1622.010, " Personnel Decontamination," Revision 7, October 14, 198 ._ .- _ _ _ _ _ - _

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-8-The licensee has. continued to make improvements in the reduction of skin contamination incidents during 1984. A total of 433 incidents were recorded, of which 265 were related to the Unit 1 outage wor The total of 433 incidents was a reduction of approximately 24 percent from the 567 incidents in 1983. The NRC inspector noted that the licensee documents contamination incidents any time an individual exhibits detectable radioactivity on their person even when a single washing with soap and water removes the radioactivity. This method of accounting results in an accurate but large total of contamination incidents. The licensee has a continuing program to reduce contami-nation incidents by stressing proper work practices.

! b. Surveys l

The NRC inspector reviewed select radiation, contamination, and airborne surveys conducted by the licensee for compliance with 10 CFR Part 20.206. The following station procedures were reviewed:

1622.001, " Radiological Surveys and Documentation," Revision 1, PC-2, September 21, 198 .002, " Radiological Evaluations and Survey Requirements,"

Revision 6, May 14, 198 .006, " Radiological Air Sampling Program," Revision 5, March 6, 198 The NRC inspector performed independent surveys of areas inside and l outside the radiological controlled areas to confirm the licensee's survey dat No violations or deviations were identified.

i c. Portable Instrumentation

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, The NRC inspector reviewed the licensee's procedures, calibration,

! and operation of instrumentation used for both routine and emergency l operations against the requirements of the ANO,' Emergency Plan and TS I and recommendations of Regulatory Guides 8.4 and 8.25 and ANSI l Standards N13.1-1969 and N323-1978.

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The NRC inspector reviewed the calibration records on select radiation l

survey instruments and daily instrument operational check record The licensee was in the process of installing a radioactive source

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for daily operational checks. The NRC inspector discussed with l licensee representatives the modification that had been made to

! certain teletector survey meters which made the two lower ranges l

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inoperable. The NRC inspector suggested'that the calibration procedure and calibration record for this instrument should be revised to reflect current radiation ranges.,

The NRC inspector reviewed quarterly-inspection checklist for -

emergency monitoring and communications equipment to determine compliance with Section H of the ANO Emergency Plan and Emergency Plan Procedure 1903.'60 " Emergency Supplies and Equipment,"

Revision 11,' January 11, 1985. The licensee had maintained the l required supplies in the Control Room Kit, Onsite Radiological l Monitoring Kit, and Technical Support Center Kit.

l No violations or deviations were identifie . Facilities and Equipment l The NRC inspector reviewed the licensee's facilities and equipment provid-l ed to implement the radiation protection program against the USAR for both j units.

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j The NRC inspector noted that the licensee had made improvements in the l access control and egress areas. A separate portable building was avail-

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able for access control and had been used on the Unit 1 turbine work.

, This portable building was used to reduce congestion at the radiological control area egress point where personnel performed surveys and returned

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their dosimetry.

l No violations or deviations were identifie . Audits

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The NRC inspector reviewed licensee audits conducted on radiation protec-

! tion activities during the period April 1, 1984 through May 31, 198 The licensee had conducted four audits during the period April 1, 1984 through May 31, 1985, which address radiation protection activities.

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These audits were:

Audit Number Dates Conducted Title SQA-1627 4/19 - 5/25/84 Chemistry, Radiochemistry, and Environmental Monitoring l SQA-1670 5/24 - 8/31/84 Training SQA-1711 8/29 - 10/30/84 Control of Measuring and Test Equipment ( SQA-1852 12/4/84 - 3/21/85 Health Physics l

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-10-In Audit SQA-1852, " Health Physics," the NRC inspector noted that the licensee had included radioactive waste activities and portable instru-mentation calibrations. Radioactive waste activities nad been a separate audit in the past performed under Procedure QAP-12, "Radwaste Management."

Procedure QAP-12 had been deleted as had QAP-17 " Environmental Monitoring."

Procedure QAP-22, " Chemistry, Radiochemistry and Environmental Monitoring,"'

Revision 1, February 21, 1985, was revised to incorporate QAP-17 element ~

The NRC inspector had previously discussed with licensee representatives (NRC Inspection Report 50-313/84-09; 50-368/84-09) that quality assurance procedures appeared to be written in a general manner and did not incorpo-rate all the necessary reference material needed to prepare a detailed l audit checklist. The licensee's procedures are still general in nature.

l The licensee has added members to the auditing department with prior l experience in health physics, instrumentation, and chemistry radio-chemistry.

l The NRC inspector noted that Audit SQA-1711, " Control of Measuring and Test Equipment," did not address radiation measuring instruments, and

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SQA-1670 " Training" included limited iformation concerning the General Employee Training Program. A licensee representative indicated that these elements would probably receive a**ention in a future audit and that all elements are not necessarily audited each tim No violations or deviations were identifie . Exit Interview l The NRC inspector met with licensee representatives and the NPC resident l inspector denoted in paragraph 1 at the conclusion of the inspection on June 28, 1985. The NRC inspector summarized the scope and findings of the i inspection es presented in this report.

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TABLE 1 Comparison of AN0's Annual Man-Rem Expenditure to National Single Reactor Performance i

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Year 1980 1981 1982 1983 1984:

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PWR Average 578 652 578 592 556:

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ANO 342 551 401 610 387:

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Table 2

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Jobs Involving Greater than 5 Man-Rem Exposure in:1985 i

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Job Description Man-Rem

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i Replace Reactor Coolant Pump C Seal 8.08

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Inspect, Remove, Replace Hydraulic /Nechanical Snubbers 10.50 Remove, Replace Steam Generator Manways 5.71 Inservice Inspection Reactor Cavities 7.13

. Sludge Lancing Steam Generators 10.46 t

! Modify Pipe Supports-Reactor Coolant Pump Piping 5.04

Extend Value Operators 6.54

Detension/ Tension Reactor Vessel Head Studs 6.94 j Remove / Replace RCS Temperature Elements 5.06

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Table 3 Procedures Reviewed:

'1000.25, " Radiological Safety Infraction / Condition Report," - Revision 3, March 22, 1985 ~

1000.31, " Radiation Protection Manual," Revision 3, March 26, 1985 ,

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! 1000.41, " Radioactive Source Accountability," Revision 6, March 23, 1985 1905.001, " Emergency Radiological Controls," Revision 0, July 9, 1984

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1905.002, "Offsite Emergency Monitoring, Revision 1, July 9,1984

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1905.004, " EOF Radiological Controls," Revision 0, March 26, 1985 1609.001, " Issue and Return of Respiratory Equipment,"

Revision 4, February 20, 1985 1609.004, " Maintenance of MSA 401 SCBA Bottle Valves,". Revision 1, April 19, 198 .008, " Decontamination of Respiratory Equipment," Revision 3, October 15, 1984 -

1609.009, " Inspection, Testing and Maintenance of Respiratory Equipement,"

Revision 4, April 19, 1985

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1609.011, " Breathing Air," Revision 4, May 22,1985

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1609.014, " Respiratory Leakage Test using the Dynatech FE-362,"

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Revision 2, February. 20, 1985 1609.015 " Testing Canisters and Respirators with the Aerosol Penetrometer,"

Revision 4 February 20, 1985-1609.017, " Testing Portable HEPA Filters," Revision 1, August 9, 1984 1609.018, " Maintenance of MSA 4500 SCBA Bottle Valves,"

Revision 0, April 23, 1985 1612.002, " Access and Control of RCA's," Revision 5, March 30, 1985 1612'.003, " Radiological Work Permits," Revision 9, March 6, 1985 1612.007, " Job Preparation and Cleanup," Revision 2, February 7, 1985.

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1612.013 " Contract HP Technician Selection," Revision 1, PC 1, l November 14, 1984

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-2-1612.016, " Reactor Building Access Control," Revision 3, November 11, 1984

.1622.001, " Radiological Surveys and Documentation," Revision 1, September 11, 1984 1622.002, " Radiological Evaluation and Survey Requirements,"

Revision 6, May 14, 1985 1622.003, Radiological Posting and Entry Requirements," Revision 6,

. September 21, 1984 1622.006, " Radiological Air Sampling Program," Revisicn 5, March 6, 1985 1622.007, "ALARA Job Coverage Practices," Revision 3, March 28, 1985 1622.008, " Marking and Handling of Radioactive Material and Equipment,"

Revision 6, April 8, 1985 1622.010, " Personnel Decontamination," Revision 7, October 15, 1984 1622.011, " Exposure Limits and Monitoring Techniques," Revision 4, March 2, 1985 1622.012, " Personnel Exposure Records," Revision l', PC-1, August 29, 1984 1622.013, "High Radiation Area Doors," Revision 2, May 22, 1985

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1622.014, " Investigation of High Unusual Exposures," Revision 1, January 10, 1985 1622.017, " Operation of a Control Point," Revision 1, April 8, 1985 1622.019, " Selecting a Survey Meter," Revision 2, April 8,1985 1622.020, " Leak Test of Sealed Sources," Revision 4, February 21, 1985 1622.021, " Radioactive Equipment Receipt, Storage and Accountability,"

Revision 2, May 9, 1985 1622.022, " Health Physics Area Inspection," Revision 4, February 21, 1985 1632.004, " Response Check of Gamma Survey Meters," Revision 3, April 8, 1985 1632.005, Portable Air Samplers," Revision 2, December 13, 1984 1632.006, " Continuous Air Monitors," Revision 2, March 25, 198 _ - _ _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ .