IR 05000313/1986005
| ML20205M209 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/25/1986 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205M195 | List: |
| References | |
| 50-313-86-05, 50-313-86-5, 50-368-86-05, 50-368-86-5, NUDOCS 8604150125 | |
| Download: ML20205M209 (10) | |
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I APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
i NRC Inspection Report:
50-313/86-OL Licenses:
OPR-51 i
50-368/86-05 NPF-6 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), Units 1 and 2
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Inspection At:
AP&L Corporate Office, Little Rock, Arkansas ANO Site, Russellville, Arkansas and surroundings Inspection Conducted:
February 18-21, 1986 Inspector:
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/J Blair Nicholas ~, Shnior Radiation Da'te Specialist, Facilities Radiological
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Protection Section
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Approved:
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8. Murray, Chief, Facilfties Radiological Date Protection Section j
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i Inspection Summary
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Inspection Conducted February 18-21, 1986 (Report 50-313/86-05; 50-368/86-05).
Areas Inspected:
Routine, unannounced inspection of the licensee's radiological i
environmental monitoring program (REMP) including:
organization and management controls; qualifications and training; radiological environmental monitoring program; meteorological monitoring program; facilities, equipment and supplies; quality control of radiological analytical measurements; quality assurance (QA)
program; contractor activities; and reportable occurrences. The inspecticn
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involved 30 inspector-hours onsite and 8 inspector-hours offsite by one.NRC inspector.
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Results: Within the areas inspected, no violations or deviations were
identified.
Three previously identified Open Items were closed.
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-3-DETAILS 1.
Persons Contacted AP&L
- M. L. Pendergrass, General Manager, Technical Services C. R. Adams, Chemical and Environmental Scientist T. C. Baker, Technical Analysis Superintendent J. D. Calloway, Chemical and Environmental Scientist
- P. L. Campbell, Plant Licensing R. D. Gillespie, Chemistry / Environmental Supervisor
- H. Greene, Supervisor, Quality Engineering T. B. Keys, Scientist, Technical Analysis Section L. Qualls, Dosimetry Technician J. R. Roberson, Supervisor, Instrumentation and Control (I&C)
- G. W. Rowlett, Scientist, Analytical Services R. B. Soloman, Scientist, Analytical Services
- D. L. Swindle, Manager, Technical Analysis Section
- P. D. Whitfield, Supervisor, Analytical Services
- Denotes those present during the exit briefing on February 21, 1986.
2.
Licensee Action on Previous Inspection Findings (Closed) Open Item (313/8503-01; 368/8503-01): Quality Assurance (QA)
Audit Team Membership - This item involved the licensee not including on the corporate QA audit team for audits of the technical analysis section (TAS) and radiological environmental monitoring activities a technical specialist knowledgeable in radiological environmental analytical activities.
The NRC inspector reviewed the audit team member qualifications for the two audits performed of the licensee's REMP since the previous NRC inspection in March 1985 and determined that each audit team included a technical specialist knowledgeable in radiological environmental monitoring programs.
This item is considered closed.
(Closed) Open Item (313/8503-02; 368/8503-02):
Environmental Monitoring Procedures - This item involved the licensee not routinely reviewing all TAS procedures and writing all the TAS procedures in the licensee's approved format.
The NRC inspector reviewed the current TAS procedures and determined that the licensee had recently completed a review of all TAS procedures for technical accuracy and had updated and written all the TAS procedures in an approved format according to Procedure TA-100,
" Administrative Control of Technical Analysis Procedures," Revision 0, November 1, 1985.
This item is considered closed.
(Closed) Open Item (313/8503-03; 368/8503-03): Quality Control of Radiological Analytical Measurements - This item involved the licensee not establishing recalibration frequencies for all radioanalytical
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instruments, performing counting geometry efficiency calibrations on a regular frequency, and establishing sample counting geometry calibrations l
to be used for quantitative analysis of all environmental sampling media.
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The NRC inspector reviewed the revised TAS procedures which define calibration and quality control check frequencies for all radioanalytical instrumentation and data associated with the recalibration and quality l
control of current counting room instrumentation and found the licensee's corrective actions satisfactory.
This item is considered closed.
3.
Inspector Observations I
The following are observations the NRC inspector discussed with the licensee during the exit briefing on February 21, 1986.
These observations are neither violations nor unresolved items.
These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement.
The licensee indicated these items would be reviewed:
a.
Training and Qualification - The licensee needs to improve their method for documenting training in accordance with the newly revised TAS training procedure.
(see paragraph 5 for details).
b.
Land Use Census Report - The licensee needs to review their method of updating program changes based on the results of the land use census survey.
(see paragraph 6 for details).
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Multichannel Analyses Calibration - The licensee needs to establish an efficiency calibration table for vegetation samples and fish t
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(see paragraph 10 for details).
4.
Technical Services Organization and Management Controls The NRC inspector reviewed the licensee's technical services organization, l
l management controls, and assignment of REMP responsibilities to verify i
compliance with commitments in Chapter 12 of the Unit 1 Final Safety
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l Analysis Report (FSAR) and Chapter 13 of the Unit 2 FSAR, requirements in l
Section 6.2 and Appendix B of the Unit 1 Technical Specifications (TS) and
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Section 6.2 of the Unit 2 TS, and AP&L TAS procedures.
a.
Organization The NRC inspector verified that the organizational structure within the Energy Supply Division at the AP&L corporate office and the TAS
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I at the central laboratory was as defined.
Since the previous NRC inspection of the REMP conducted in March 1985, there has been one personnel change.
The radiological analysis group of the TAS has-added a third scientist to its staff.
The current'TAS organizational structure and staffing appeared to be consistent with REMP l
requirements.
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-5-b.
Management Controls The NRC inspector reviewed the TAS administrative control procedures, TAS position descriptions, and ANO procedures for the assignment of responsibilities for the management and implementation of the REMP.
The NRC inspector verified that the administrative control responsi-bilities identified in the FSAR and TS were being implemented and duties and responsibilities appeared to be as described by procedure.
No violations or deviations were identified.
5.
Qualifications and Training The NRC inspector reviewed the qualifications and training of the ANO chemistry / environmental section staff and the TAS staff located at the central laboratory in Little Rock to determine compliance with commitments in Chapters 12.1.3 and 12.2 of the Unit 1 FSAR and Chapters 13.1.1 and 13.2 of the Unit 2 FSAR, and the requirements in Sections 6.3 and 6.4 of the Unit 1 and Unit 2 TS, and TAS procedures.
The NRC inspector reviewed the resumes for each TAS analytical services staff member and determined that the staff met the experience and educational qualifications as committed to in the FSAR and TS.
The ANO chemistry / environmental staff is responsible for collection, documentation, and shipment of the radiological environmental samples collected around the ANO site.
Training related to the REMP sampling program is conducted by the chemistry / environmental section as on-the-job training. The NRC inspector reviewed the trainino and qualification records for the day shift chemistry / environmental technicians and verified that they all had received the required sample collection training.
The NRC inspector discussed the trainir.g program for TAS personnel with the analytical services supervisor. Training required to perform the analytical analyses is conducted in the central laboratory as on-the-job training by the senior TAS staff.
The NRC inspector reviewed the TAS training procedure TA-101, " Training of Technical Personnel," Revision 0, November 1, 1985, and noted from the review of the TAS training records that the training procedure had not been fully implemented for the revised training program.
The NRC inspector's review of the training and qualification records for each of the three scientists assigned to perform radioanalytical analyses associated with the REMP indicated that each had not received training on all newly revised analytical procedures.
This matter was discussed with the licensee at the exit briefing and expressed as an inspector observation which should be evaluated by the licensee.
The NRC inspector, at the exit briefing, suggested that all TAS radiological analysis staff should receive documented training in accordance with TA-101 which would certify for each individual all tasks which titt individual may have occasion to perfor.
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-6-The licensee indicated that this training and documentation would be completed as soon as possible for the TAS staff.
The NRC inspector considered the above observation was not significant enough to impact on the performance of the present REMP and was not considered a major problem since the NRC inspector determined that the present staff members had been involved in writing the recently revised procedures and had sufficient experience to perform their assigned responsibilities.
No violations or deviations were identified.
6.
Radiological Environmental Monitoring Program The NRC inspector reviewed the licensee's REMP to determine compliance with requirements in Sections 4.30 and 6.12.2.5a and Appendix B of the Unit 1 TS and Sections 3/4.12 and 6.9.4 and Appendix B of the Unit 2 TS and ANO and TAS procedures.
The licensee had amended the Radiological Effluent Technical Specifications (RETS) for Units 1 and 2 effective January 1, 1985, to be in agreement with the format in NUREG-0472 and replace Appendix B-environmental technical specifications. Amendment No. 68 to the Facility Operating License No. NPF-6 for ANO, Unit 2, was issued August 9, 1985, to delete Appendix B requirements from the ANO Unit 2 TS.
A similsr amendment to delete Appendix B requirements from ANO Unit 1 TS is still pending final approval from the NRC Office of Nuclear Reactor Regulations (NRR).
The NRC inspector reviewed the annual radiological environmental monitoring report for 1984 and determined that related Appendix B TS sampling and analysis requirements had been met.
A review of current REMP activities indicated that the RETS requirements were being implemented.
The NRC inspector reviewed the licensee's procedures for implementation of the REMP.
The procedures for administration of the REMP, collection of environmental samples, and analytical procedures to meet TS analysis requirements were written with sufficient detail to ensure TS compliance.
The NRC inspector reviewed the annual land use census which was conducted during the period August 29-30, 1985.
The NRC inspector noted that the drafted 1985 land use census report did not include and identify the location of the nearest milk animal and the nearest residence in each of-the 16 meteorological sectors within a distance of'S miles from the plant site.
This observation was discussed with the licensee at the exit briefing.
The licensee inforned the NRC inspector that additional work would be performed to complete the land use census in accordance with TS requirements and the results of the land use census will be reported in the 1985 annual REMP repor.
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-7-The NRC inspector reviewed the licensee's Offsite Dose Calculation Manual (0DCM) and verified that it had been approved by NRR and had been implemented as of January 1,1985. No changes had been made to the ODCM except for the addition and deletion of specific sample stations designated in Table 4.1 to establish required sampling stations for milk and food products as defined in the RETS.
The licensee participates in the U.S. Environmental Protection Agency's (EPA) Environmental Radioactivity Laboratory Intercomparison Program.
The NRC inspector reviewed the licensee's results of the cross check sample analysis comparisons and found most of the licensee's results were within the EPA's acceptance criteria of three standard deviations of the known values supplied by the EPA.
The NRC inspector reviewed the calibration program for the REMP air samplers.
The NRC inspector reviewed the ANO environmental TLD program.
The licensee had approved procedures for the processing and dose reporting from environmental TLD badges.
The licensee participates in the International Intercomparison of Environmental Dosimeters program biannually.
The NRC inspector reviewed the program results for 1982 and 1984.
No violations or deviations were identified.
7.
Meteorological Monitoring Program The NRC inspector reviewed the licensee's meteorological monitoring program to determine compliance with requirements in Section 4.30 and Appendix B of the Unit 1 TS and Section 3/4.12 and Appendix B of the Unit 2 TS, requirements of Supplement 1 to NUREG-0737, recommendations of Regulatory Guides 1.23 and 1.97 and American National Standards Institute (ANSI-ANS) Standard 2.5 - 1984, and ANO procedures.
The NRC inspector reviewed the meteorological tower, data recording equipment, calibration procedures, and calibration records.
It was verified that the meteorological tower instrumentation had been calibrated quarterly during 1985.
The NRC inspector reviewed the status of the installation of the new meteorological tower, instrumentation, and data recording equipment.
It was noted that the installation of the new meteorological tower and instrumentation was almost complete and operability testing was scheduled for March 1986.
The licensee anticipates placing the new tower in service upon successful cor.pletion of instrument calibration and operability testing.
No violations or deviations were identified.
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Facilities, Equipment, and Supplies The NRC inspector inspected the AP&L central laboratory facilities in Little Rock, Arkansas, including the environmental sample receiving and storage area, environmental sample preparation laboratory, radiochemistry laboratory, and radiochemistry counting room.
The laboratory areas inspected were equipped with the necessary chemicals, labware, and analytical instrumentation to perform the required analytical procedures.
The licensee had expanded the sample receiving and storage area and upgraded the radiochemistry laboratory with a new hood and laboratory bench space since the previous inspection.
The radiochemistry counting room was equipped with sufficient counting instrumentation to perform TS requirements.
The central laboratory facilities and equipment appeared to be adequate to accomplish the REMP laboratory requirements.
No violations or deviations were identified.
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Radiological Environmental Monitoring Procedures The NRC inspector reviewed the licensee's procedures for environmental media sample collection, sample preparation, and sample analysis to determine compliance with AN0 TS.
The ANO plant procedures for administration of the REMP and collection of environmental samples were reviewed.
The NRC inspector reviewed the TAS procedures which had been written to meet TS requirements.
The NRC inspector noted that the licensee had reviewed all TAS procedures and revised them as required for technical accuracy and had rewritten them in an approved format according to Procedure TA-100, " Administrative Control of Technical Analysis Procedures," Revision 0, November 1, 1985.
No violations or deviations were identified.
10. Quality Control of Radiological Analytical Measurements The NRC inspector reviewed the TAS program for calibration and quality contral of radiological analyticai measurements to determine compliance with Section 4.30 and Appendix B of the Unit 1 TS and Section 3/4.12 and Appendix B of the Unit 2 TS, TAS procedures, and the recommendations in Regulatory Guide 4.15.
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The NRC inspector reviewed the TAS quality control procedures, counting instrument's calibration data and performance check data, and other documentation of instrument performance.
Data for the year 1985 were reviewed.
The quality control procedures appeared to be adequate and the records and data associated with the quality control of the counting instruments were presented according to procedur._____
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-9-The NRC inspector reviewed the TAS calibration data for the Nuclear Data Multichannel Analyzer System generated during the 1985 recalibration and made the following observation which was discussed with the licensee at the exit briefing as an item which could improve the laboratory program.
The licensee had completed in 1985 a recalibration of the multichannel analyzer system and had established new efficiency tables for all cooperative agreement sample media except vegetation and fish.
The licensee agreed at the exit briefing on February 21, 1986, to evaluate the need for counting geometry efficiency tables for vegetation and fish samples and take corrective action as necessary.
The NRC inspector noted that even though no detectable levels of radioactivity had been identified in vegetation and fish samples; however, efficiency tables should be established for these sample media.
No violations or deviations were identified.
11. QA Program The NRC inspector reviewed the licensee's QA audit program to determine compliance with commitments in Chapter 18 of the Quality Assurance Manual and requirements in Section 6.5.2.8 of the Unit 1 and Unit 2 TS.
The NRC inspector reviewed the REMP audits conducted since the previous NRC inspection conducted in March 1985.
The following audits were reviewed:
Little Rock General Office Technical Analysis Audit, QAP-28-85, a.
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May 25-31, 1985.
b.
Chemistry, Radiochemistry, and Environmental Monitoring Audit, QAP-22-85, October 10 through December 17, 1985.
Louisiana Power & Light QA Audit of Little Rock General Office c.
Technical Analysis Section, A39.279-85.1, November 6-7, 1985.
The NRC inspector reviewed the audit procedures and checklists.
The NRC inspector noted that the QA audits were designed to determine compliance with the TS and REMP and TAS procedures.
The audit findings and the licensee's responses were reviewed and the NRC inspector confir;ned that t
the audit findings had received management's attention and that the responses and corrective actions to the audit findings had been addressed and documented in a timely manner and in accordance with QA procedures.
The NRC inspector noted that the audit teams performing the REMP audits included a lead auditor qualified to the requirements of ANSI /ASME N45.2.23 - 1978 and a qualiried technical specialist knowledgeable in radiological environmental analytical activities.
The audit performed in May 1985 of TAS was conducted by the AP&L corporate QA audit team which was assisted by a technical specialist from Mississippi Power and Light.
Louisiana Power and Light performed an independent audit of TAS in November 1985.
The purpose of the two additional Middle South Utilities assisting and performing audit activities of TAS was to verify that the
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-10-Little Rock General Office Technical Analysis group could provide radiological environmental sample analysis services for Mississippi Power and Light and Louisiana Power and Light to meet their respective TS.
No violations or deviations were identified.
12.
Contractor Activities The licensee uses contractors only to perform sampling of fish, bottom sediment, and some milk locations.
All AP&L environmental sample analyses are performed in the AP&L TAS central laboratory in Little Rock except for the TLDs which are processed by ANO staff. The NRC inspector reviewed the licensee's audit program for contractor activities associated with the REMP and found the program adequate.
No violations or deviations were identified.
13.
Reportable Occurrences The NRC inspector reviewed licensee event reports and the 1984 Annual Environmental Monitoring Report for reportable occurrences dealing with the REMP to determine compliance with reporting requirements of Section 6.12 of Unit 1 TS and Section 6.9 of Unit 2 TS.
The NRC inspector found no reportable events.
No violations or deviations were identified.
14.
Exit Briefing The NRC inspector met with the licensee representatives denoted in paragraph 1 of this report at the conclusion of the inspection on February 21, 1986.
The NRC inspector summarized the-purpose and scope of the inspection and discussed the inspection findings as presented as observations in this report.
The licensee agreed to evaluate and take appropriate action on the inspector observations in order to resolve the NRC inspector's concerns.
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