IR 05000313/1987001
| ML20211Q812 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/13/1987 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20211Q741 | List: |
| References | |
| 50-313-87-01, 50-368-87-01, NUDOCS 8703030192 | |
| Download: ML20211Q812 (9) | |
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U.S. hJCLEAR REGULATORY COMMISSJ.ON
REGION IV
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NRC Inspection Report: 50-313/87-01 Unit 1
" Licenses: ItR-51 y
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50-368/87-01 Unit 2 NPF-6
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- Doc ket'i: 50-313
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50-368
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~ Licensee: Arkansas Pcwer & Light Company (AP&L)
P. O. Box 551
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Little.Rockj Arkansas 72203
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Facility Name. Arkansas'Nu' clear One (ANO)
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Inspection At: -ANO Site, Russellville, Pope County, Arkansas
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Inspection Conducted: January 19-23, 1987
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In'spe$t'or:
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2/O/f7 O M Picholas,, enior Ridiation Specialist _
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gFacilities Radi'a11on Protectioi Section o
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Approved:
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B.Murray, Chief,FacilitieyRadiologica1 Date Protection Section
Inspection Summary Inspection Corpucted January 19-23, 1987 (Report 50-313/87-01; 50-368/87-01)
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I Areas Inspegted:
Routine, unannounced insppction of the licensee's liquid and gasecus radlaactive waste management programs including orgsnization and
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management controls, training and qualifications, radioactive waste effluent
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releases, records and reports of radioactive effluents, radioactive waste effluent release procedures, reactor coolant and secondary water quality, quality control of analytical mopsurements, and quality assurance (QA) program.
Results: Within the areas' inspected, three violattens were ' identified (failure
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to meet health physics ~ personnel qualifications, paragraph 2; fatture to
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perform labordtory analyses, paragraph 5.b; and failure to report ridwaste
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effluent radiation doses, paragraph 6).
No deviati s were ident:!fied.
L 0703030192 070pp4 hDR ADOCK 05000313
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DETAILS 1.
Persons Contacted AP&L
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- J. M.-Levine, Director of Site Nuclear Operations
- T. C. Baker, Technical Support Manager B. A. Baker, Operations Manager B. L. Bata, QA Engineer E. E. Bickel, Health Physics (HP) Superintendent
- P. L. Campbell, Plant Licensing Engineer
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R. M. Cooper, QA En: neer
- E. C. Ewing, General Manager, Plant Support
- G. L. Fiser, Nuclear Quality Specialist, QA M. E. Frala, Assistant Radiochemistry Supervisor
- R. D. Gillespie, Technical Analysis Superintendent M. P. Goad, Operations Trainer II, Unit 1 W. L. Hada, HP Supervisor D. C. Harris, Lead Trainer, Chemistry / Radiochemistry
- L. G. Hodges, Training Instructor, Chemistry / Radiochemistry
- D. R. Howard, Special Projects Manager G. T. King, Operations Trainer II, Unit 2 D. O. Lomax, Plant Licensing Supervisor
- W. C. McCord, Quality Control (QC) Supervisor, Nuclear Quality
- W. C. McKelvy, Assistant Radiochemistry Supervisor
- W. R. Pool, Assistant Radiochemistry Supervisor
- G. D. Provencher, QA Supervisor, Nuclear Quality'
T. M. Rolniak, Lead HP Trainer J. L. Taylor-Brown, QC Supervisor Others i
- W. D. Johnson, Senior NRC Resident Inspector C. C. Harbuck, NRC Resident Inspector
- Denotes those present during the exit briefing on January 23, 1987.
2.
Allegation Followup (Case 4-86-A-115)
On November 21, 1986, an anonymous alleger called NRC Region IV and talked with the allegations coordinator. The allegation was made that unqualified personnel were being promoted from junior health physics technicians to senior health physics technicians at ANO. The alleger stated that ANSI standards list a minimum of 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> of related technical experience as one of the requirements needed to qualify as a senior health physics technician. The alleger named five ANO contract health physics personnel whc were believed to be promoted to senior health physics technician nositions without meeting the required minimum i
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number of experience hours to qualify. The alleger stated that these promotions had been made with the full knowledge of three named health physics supervisors. The alleger was concerned about the possible safety hazard of having unqualified senior health physics technicians serving in responsible positions.
Technical Specification (TS) 6.3.1 for Units 1 and 2 states, "Each member of the unit staff shall meet or exceed the minimum qualifications of
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ANSI N18.1-1971 for comparable positions,...." This unit staff qualification is further defined in health physics administrative procedure, 1612.013, " Contract HP Technician Selection," Revision 2, dated October 5, 1986, which states in paragraph 4.1, " Senior Health Physics Technician - A contractor health physics technician who meets the following minimum standards:
. shall have a minimum of 2 years
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(4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> in a minimum of 80 weeks) of varied radiological protection experience in commercial nuclear power stations or their equivalent."
Based on an allegatiori made on November 21, 1986, totheNRCpegionIV allegation coordinator, the NRC inspector reviewed the resumes and training records of.the five contract health physics technicians named in the allegation. Contrary to the above requirements, on January 23, 1987, the NRC inspector determined that one of the five contract health physics technicians named in the allegation was oromoted to a senior health physics technician position prior to meet.ng the minimum of 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> of radiological protection experience.
Prior to being promoted to senior health physics technician at ANO, the junior health physics technician had accumulated only 2855 credit hours of radiological protection' experience.
The promotion of a junior health physics technician to a senio^' health physics technician prior to meeting the minimum radiological protection experience is an apparent violation of Units 1 and 2 TS 6.3.1.
(313/8701-01,368/8701-01)
'3.
Organization and Management Controls The NRC inspector reviewed the licensee's organization and staffing regarding the radioactive waste effluent program (RWEP) to determine agreement with commitments in Chapter 12.1 of the Unit 1 Updated Safety Analysis Report (USAR) and Chapter 13.1 of the Unit 2 USAR and the requirements in Section 6.2 of Units 1 and 2 TS.
The NRC inspector verified that the organizational structure of the ANO radwaste effluents operations section and radiochemistry section were as defined in the USAR and TS.
Since the previous NRC RWEP inspection in February 1986, the positions of radiochemistry supervisor and chemistry and environmental supervisor have been abolished and a new position of technical analysis superintendent has been established and filled to oversee the activities of radiochemistry, secondary chemistry, and environmental programs.
The ANO management control procedures and position descriptions were reviewed for the assignment of ' responsibilities l
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-4-for the management and implementation of the ANO RWEP. The NRC inspector verified that the administrative control responsibilities specified in ANO procedures were being implemented.
The NRC inspector reviewed the staffing of the radwaste control operators section and the radiochemistry section and determined that both sections were fully staffed.
No violations or deviations were identified.
4.
Training and Qualifications The NRC inspector reviewed the training and qualifications of the radiochemistry staff and waste control operators (WCO) responsible for the RWEP to determine agreement with commitments in Chapter 12 of the Unit 1 USAR and Chapter 13 of the Unit 2 USAR and the requirements in Sections 6.3 and 6.4 of Units 1 and 2 TS.
The NRC inspector reviewed the qualifications of selected radiochemistry staff and WC0 responsible for the implementation of the RWEP and determined that they met the required qualifications specified in the USAR and TS.
The NRC inspector reviewed the training programs for radiochemistry personnel and WCO, including a review of position task analyses, training procedures, course summaries, lesson plans and objectives, training records, and qualification cards. The NRC inspector found that the licensee's training program was being implemented in accordance with ANO procedures.
The NRC inspector reviewed training records and qualification cards for selected radiochemistry personnel and WC0 responsible for performing RWEP activities. The NRC inspector verified that the radiochemists and WC0 had completed the required training on radiological effluent releases and radwaste systems to perform their functional area assignments.
No violations or deviations were identified.
5.
Radioactive Waste Effluent Releases The NRC inspector reviewed the licensee's liquid and gaseous radwaste processing systems, procedures, and records associated with liquid and gaseous releases to determine agreement with commitments in Chapter 11 of the Units 1 and 2 USAR and the recuirements in Sections 3.25, 4.29, and 6.14 of the Unit 1 TS and Sections 3/4.11 and 6.14 of the Unit 2 TS, offsite dose calculation manual (CDCM), and the design objectives of 10 CFR Part 50, Appendix I.
The NRC inspector determined that the licenset. had implemented the radiological effluent technical specifications (RETS). The NRC inspector reviewed the implementation of the RETS and ODCM to ensure agreement with
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revised analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, program operating procedures, and offsite dose results from liquid and gaseous effluents.
a.
Liquid The NRC inspector reviewed a representative number of liquid release permits for the period January 1985 through December 1986.
It was determined that processing, sampling and analysis, approval, and performance of the releases were conducted in accordance with ANO procedures. Quantities of radioactive nuclides released in the liquid effluents were within the limits specified in the RETS.
Offsite doses had been calculated acccrding to the ODCM and were within the TS limits.
The NRC inspector determined that no design changes had been made to the liquid waste management system since the previous NRC inspection conducted in February 1986.
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Gaseous The NRC inspector reviewed selected gaseous waste release permits which included unit vent continuous releases and batch releases from waste gas decay tanks and containment from both Units 1 and 2 for the period January 1985 through December 1986.
It was determined that the gaseous waste releases were being performed according to ANO procedures and the gaseous radioactive nuclides released were within the limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within the TS limits. The NRC inspector reviewed the licensee's analyses results to determine compliance with the requirements of TS 4.29.2.1 and Table 4.29-3 in the Unit 1 TS and the requirements of TS 3/4.11.2.1 and Table 4.11-2 in the Unit 2 TS. The licensee's TS 4.29.2.1B for Unit I states,
"The dose rate in unrestricted areas,... shall be determined in accordance with the ODCM... by using the sampling and analysis program, specified in Table 4.29-3" and TS 3/4.11.2.1.2 for Unit 2 states, "The dose rate... shall be determined... in accordance with the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 4.11-2."
The respective TS Tables 4.29-3 and 4.11-2 require a monthly gross alpha analysis of unit vent air particulate samples.
Contrary to the above, the NRC inspector determined on January 22, 1987, that the licensee had been performing only quarterly gross alpha analyses on unit vent air particulate samples during the period January 1,1985, through December 31, 1986.
The NRC inspector also noted that the licensee's procedure 1042.003,
" Routine Surveillance Schedule and Technical Specification Reporting," Revision 5, dated October 9, 1986, refers to schedule Form 1042.001GG.
Form 1042.001GG addresses unit vent sampling and analysis indicating weekly gamma isotopic and tritium analyses, but it does not include the monthly and quarterly unit vent sampling and analyses TS requirements. The NRC inspector reviewed procedure 1604.015, " Analysis of Unit Vent and Condenser Vacuum
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Pump," Revision 6, dated January 30, 1986, which addresses the weekly, monthly, and quarterly sampling and analysis TS requirements for unit vents.
It was noted that paragraph 8.3 stated the frequency for gross alpha analysis of unit vent air particulate samples as quarterly rather than monthly as required by the TS. The performance of gross alpha analyses on unit vent air particulate samples less frequently than required by TS is an apparent violation of Unit 1 TS Table 4.29-3 and Unit 2 TS Table 4.11-2.
(313/8701-02; 368/8701-02)
No deviations were identified.
6.
Records and Reports of Radioactive Effluents The NRC inspector reviewed the licensee's records and reports concerning radwaste systems and effluent releases for compliance with the requirements of 10 CFR Part 50.36(a)(2) and Section 6.12.2.6 of the Unit 1 TS and Section 6.9.3 of the Unit 2 TS.
The NRC inspector reviewed the semiannual effluent release reports for the periods January 1 through June 30, 1985, July 1 through December 31, 1985, and January 1 through June 30, 1986. These reports included a quarterly summary of quantities of radioactive liquid and gaseous effluents released from each unit written in the format described in NRC Regulatory Guide 1.21.
The NRC inspector reviewed the implementation of RETS for the period January 1, 1985, through December 31, 1986, to determine agreement with the Units 1 and 2 TS. The licensee's TS 6.12.2.6(e)2 and 3 for Unit I and TS 6.9.3.4(2) and (3) for Unit 2 states that the first report filed each year shall contain a summary of radiation doses due to radiological effluents during the previous calendar year calculated in accordance with the methodology specified in the Offsite Dose Calculation Manual.
The report shall also include the radiation dose to members of the public due to their activities inside the site boundary.
This calculated dose shall include only those dose contributions directly attributed to operation of the unit and shall be compared to the limits specified in 40 CFR 190.
Contrary to the above, the NRC inspector determined on January 21, 1987,
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that the licensee had not included in the first semiannual effluent release report filed in 1986 a summary of radiation doses due to radiological effluents released to the environment during the previous r
calendar year (1985) nor did the report contain the radiation dose to members of the public due to their activities inside the site boundary.
The failure to report offsite doses due to radiological effluents for the previous calendar year and failure to report radiation doses to members of the public due to their activities inside the site boundary and compare those dose contributions to the limits specified in 40 CFR 190 are apparent violations of Unit 1 TS 6.12.2.6.e(2) and (3), and Unit 2 TS 6.9.3.4(2) and (3).
(313/8701-03; 368/8701-03)
No deviations were identified.
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Radioactive Waste Effluent Release Procedures The NRC inspector reviewed the licensee's effluent release procedures to determine compliance with the requirements in Sections 3.25, 4.29, and 6.8 of the Unit 1 TS and Sections 3/4.11 and 6.8 of the Unit 2 TS.
The NRC inspector reviewed current approved revisions of ANO procedures governing the release of liquid and gaseous radioactive waste. The NRC inspector determined that the effluent release procedures included the following features:
sampling of-radioactive waste effluent chemical and radionuclide analyses prior to release calculation of effluent release rates and projected offsite doses prior to release calculation of effluent radiation monitor setpoints testing effluent isolation valves prior to release
recording effluent dilution during release verifying discharge flow rates and effluent volume discharged using checklists for the operation of both liquid and gaseous waste effluent discharge systems including shift supervisor's approval signature No' violations or deviations were identified.
8.
Reactor Coolant and Secondary Water Quality The NRC inspector reviewed the licensee's program for monitoring and controlling the reactor coolant and secondary water quality to determine agreement with commitments in Chapters 4 and 9 of the Unit 1 USAR and Chapters 5 and 9 of the Unit 2 USAR and the requirements in Sections 3.1 and 3.10 of the Unit 1 TS and Sections 3/4.4.7 and 3/4.7.1.4 of the Unit 2 TS.
The NRC inspector reviewed selected reactor coolant and secondary water chemistry analysis log sheets for the period January through December 1986.
The records reviewed indicated that all required sampling and analyses were performed at the frequencies required by the TS and the analyses results met TS requirements.
No violations or deviations were identified.
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9.
Quality Control of Analytical Measurements The NRC inspector reviewed the licensee's program for calibration and quality control of chemical and radiochemical analytical measurements to determine compliance with the requirements in Section 6.8 of Units I and 2 TS.
The NRC inspector inspected the licensee's radiochemistry laboratory, secondary chemistry laboratory, and radiochemistry counting room instrument calibration and quality control procedures, counting instrument calibration data and quality control data.
No violations or deviations were identified.
10. QA Program The NRC inspector reviewed the licensee's QA audit program regarding radwaste activities associated with liquid and gaseous effluent releases and implementation of RETS to determine agreement with commitments in Chapter 13.4 of the USAR and requirements in Section 6.5 of the Units 1 and 2 TS.
The NRC inspector reviewed the QA department organization, audit schedules for 1986 and 1987, and the qualifications of auditors.
It was noted that a nuclear. quality specialist had been added to the QA staff during a recent r2 organization who was knowledgeable and experienced in chemistry / radiochemistry programs at nuclear power facilities.
Selected QA audit reports generated from audits performed during 1985 and 1986 in the areas of health physics /radwaste (QAP-3-85) and chemistry / radiochemistry / environmental monitoring (QAP-22-85 and QAP-22-86)
were reviewed for scope to ensure thoroughness of program evaluation and timely follow-up of identified findings. The NRC inspector found the audit plans and checklists to be comprehensive and the responses and corrective actions to audit findings timely. The NRC inspector reviewed the resolution of Surveillance Finding Reports SFR1-636 (June 6, 1985),
SFRI-633 (March 27, 1985), SFR-021 (May 9, 1985), and Quality Assurance Report QAR-63 (June 27, 1985) documented in NRC Inspection Report 313/8528; 368/8529 and noted all the findings and concerns had been closed.
I The NRC inspector determined that the licensee was using a contractor laboratory to perform the Fe analysis on radioactive liquid waste effluent required by TS. The licensee had performed a vendor QA audit of the contractor and had placed the contractor on the ANO approved vendor list.
No violations or deviations were identified.
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Exit Briefing The NRC inspector met with the NRC senior resident inspector and the licensee representatives identified in paragraph I at the conclusion of the inspection on January 23, 1987. The NRC inspector summarized the scope of the inspection and discussed the inspection findings.