IR 05000313/1987024
| ML20236A324 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/13/1987 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236A314 | List: |
| References | |
| 50-313-87-24, 50-368-87-24, NUDOCS 8710220187 | |
| Download: ML20236A324 (8) | |
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APPENDIX U.S. NUCLEAR REGULATOR'Y COMMISSION'
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' REGION:IV
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NRC' Inspection Report:
50-313/87-24 Licenses:
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50-368/87-24 NPF-6
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Docket:
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50-368~
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Licensee:
Arkansas Power 'and Light Company (AP&L)
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P. O Box.551'
Little Rock, Arkansas
,72203 Facility.Name: ' Arkansas Nuclear 0ne:(ANO)
.. Inspection At:.ANO Site, Russellville, Pope County, Arkansas and the'AP&L Environmental Laboratory, Little Rock, Arkansas Inspection Conducted:
September 8-11,- 1987
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Inspectar:
/I h /)/f50 0/
/Of/3/$
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.n C%nTy, Ratiiation Spe/ialist, Facilities Date '
g Radiological Protection Section'
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Approved:
/1[AA N[//j[////
/8// _M B?Mtntay', Chief, Facilit'
Radiological Dife,/
Protection ~Section
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Inspection Summary
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Inspection' Conducted September 8-11,,1987 (Reports 50-313/87-24; 50-368/87-24).
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Areas Inspected:
Routine, unannounced inspection of the licensee's
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f radiological environmental monitoring program.
i Results:
Within.the areas inspected no violations or deviations were l
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l 8710220187 871020
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DETAILS
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1.
Persons Contacted
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AP&L l
- J. T. Enos, Nuclear Engineering'& Licensing Manager
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- M. W. Tull, Nuclear Safety & Licensing Specialist j
- T. D. Reed, Technical Analysis Section Manager l
T. C. Baker, Technical Support Manager j
R. D. Gillespie, Chemistry / Environmental Supervisor
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D. D. Snellings, Nuclear Programs Manager
- R. W. Peckham, Health Physics Specialist
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D. B. Lomax, Plant Licensing Supervisor
- P. D. Whitfield, Environmental Services Supervisor, Acting J. H. Beard, Analytical. Services-Supervisor, Acting
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- G. W. Rowlett, Environmental. Laboratory Scientist T. Keys, Environmental Laboratory Scientist R. B. Soloman, Environmental Laboratocy Scientist R. E. Green, Dosimetry Supervisor'
D. Meatheny, Chemistry Technician
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l J. R. Roberson, Instrument and Controls (I&C) Supervisor C. R Adams, Site Biologist.
- Denotes attendance at the exit interview on September 11, 1987, i
2.
Inspector Observations
The following are observations the NRC inspector discussed witii the j
licensee during the exit interview on September 11, 1987.
These i
observations are not violations, deviations, unresolved items, or open l
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.
Procedures - The Technical Analysis Section procedures do not include procedures for handling radioactive samples, applicability of state and NRC byproduct license conditions, spill cleanup procedures, use of safety equipment, and the disposal of radioactive samples, b.
Annual Environmental Report - The dates that the land use census was performed are not included in the report, j
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Final Safety Analysis Report.- The meteorological data and dispersion
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factors for ANO have not been validated or updated in approximately 20 years, i
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Sample Counting - ANO has not established a routine program for
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providing the environmental laboratory with unu' sed particulate i
filters and charcoal cartridges'in order'to determine the background f
radiation levels associated with the filters and cartridges, j
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Precipitation Collection - The taped joints that couples the l
collection funnel to the' sample collection container.on several of q
the precipitation collectors are in'need of repair.
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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 matters of concern to the NRC inspector.
The following open items were identified:
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l Open Item Title See Paragraph I
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313/8724-01 &
Accredited training program for
368/8724-01 analytical section chemists 313/8724-02 &
I&C Training on meteorological
368/8724-02 system 313/8724-03 &
Commercial harvesting of buffalo
368/8724-03 fish in Lake Dardanelle 313/8724-04 Radioactivity in sanitary
368/8724-04 system sand-filter beds 313/8724-05 &
Comparison of the dosimeter used for
368/8724-05 environmental monitoring to ANSI N545-1975 guidance 313/8724-06 &
Meteorological system calibration
368/8724-06 368/8724-07 Meteorological system description
in the FSARs 313/8724-08 &
AN0 Plant Safety Committee review of
368/8724-08 Analytical Services Group procedures
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4.
Program Areas Inspected The following program areas were inspected.
These program areas and inspection procedures are addressed in NRC Manual Chapter 2500.
Unless otherwise noted, the inspection was completed and revealed no violations,
deviations, unresolved items, or open times.
Notations after a specific i
inspection item are used to identify the following:
I = item not
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s inspected or only partially inspected; V = violation; O = deviation; i
U = unresolved item; and 0 = open item.
t Procedures Inspection Requirements 83522 Organization and Management Controls (Environ, ental)
02.01 - Organization Responsibilities, and Authorities 02.02 - Staffing 02.03 - Identification and Correcticn of Weaknesses
02.04 - Audits and Appraisals 02.05 Communication to Employees
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02.06 - 0ccumentation and I<nplementation - 0, See paragraph 8 83722 Organization and Management Controls (Environmental)
02.01 - Organization 02.02 - Staffing 02.03 - Radiation Protection Manager - I 02.04 - Identification and Correction of Weaknesses 02.05 - Audits and Appraisals 83723 Training and Qualifications (Environmer.tal)
02.01 - Adequacy of Trainirig 02.02 - Employee Training
02.03 - Transportati.on/Radwaste Training -I 02.04 - Qualification Requirements 02.05 - New Employees 02.06 - INP0 Accreditation 02.07 - Audits and Appraisals 02.08 - Training Not Covered by INP0 - 0, See paragraph 5 80521 Radiological Environmental Monitoring 02.01 - Implementation of the Radiological Environmental Monitoring Program-02.02 - Implementation of the Meteorological Monitoring Program 02.03 - Facilities, Equipment, and supplies 02.04 - Documentation 02.05 - QA Program 02.06 - Contractor Activities - I 80721 Radiological Environmental Monitoring 02.01 - Audits and Appraisals 02.02 - Changes - 0, See paragraph 6
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'E 02.03 - Implementation of the Environmental
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Monitoring Program. '0,'See paragraph 6 02.04 -' Implementation of the Meteorological.
Monitoring Program
- 0,- See paragraph 7 02.05:- QA' Program
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g 02.06 - Contractor'Activ'ities
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90713 Review'of!PeriodicIndSpecialReports 02.01 - Report Content 02.02 -' Verify Test Results 02.03 - Ascertain. Adequacy of_ Corrective Actions-d
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02.04 - Determine Classification of Report Contents:
.02.05 - Document Review and Closecut 5.
Training The NRC inspector determined that~ the' radiochemist working in the AP&L Environmental Laboratory (EL) in Little Rock, Arkansas (General Office H
location) were being provided periodic on-the-jo'r training (0JT) by the -
Analytical Services Supervisor and other staff members.
An in-house; (Technical Services Section) trair>ing program had been developed and..
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implemented per Technical Analysis Procedure 101, Training of Technical
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Personnel." However, the NRC inspector noted that the oncite radiochemist J
have a formal performance based training program that was developeo'for
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INPO accreditation.
The NRC inspector also noted that the EL radiocbamists performed TS surveillance. work and. radiochemical analyses as' technically
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complicated as those performed by_onsite radiochemist, but were_ noti
provided a formal training and qualification-program as.had been developed-l for onsite radiochemist.
Representatives in the:onsite training.
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department provided no reasons why ths El personnelishod d not;be included in a formal training and qualification program based on tho. complexity of their duties and the importance ofttheir serv;ces. -This'is considered an-open item pending further licensee evaluation'of the. training needs of_EL radiochemistry personnel (313;368/8724-01).
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Also during this inspection, it was noted thatJthe OJT portion of the formal performance based training program for I&C technicians'does not
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include surveillance and calibration of_the meteorological equipment and j
instrumentation.- The NRC inspector noted that severa1DI&C~ technicians
have received.special vendor training on the meteorological equipment and.
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perform calibration of the meteorological _ equipment._ Discussions with
Training Department representatives' indicated that:the equipment associated with the meteorological monitoring tower does not present any
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unique ' equipment or require any greater technical knowledge than for other l
plant equipment.
The licensee did.not provi_de'any~ reason.as to why training on calibration procedures and inclusion of the meteorological 1'
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monitoring equipment calibration activiti_es into the 0JT program would not improve personnel performance and ensure that future I&C technicians'
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receive appropriate training for these instruments.
This is considered as open item pending licensee review of the~ training needs of personnel-
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6 performing surveillance and calibrations on meteorological monitcring equipment and instrumentation (313;368/8724-02).
6.
Radiological Monitoring Program l
During a review of the collection of environmental samples identified in
the Radiological Effluent Technical Specifications (TS 4.30 and TS 3/4.12, of Units 1 & 2, respectively), the NRC inspector determined that commercial fishermen (six or more) were harvesting approximately 2,000 pounds of buffalo fish per week from Lake Dardanelle for delivery to Kansas City food markets /restuarants.
Currently, the licensee only samples catfish, crappie, or bass semiannually for determining the general population's radiation exposure via the food chain pathway for bottom feeders and sport fish.
Section 2.1.4.3 and Table 2.1.9 of the Unit-2 FSAR addresses the
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l commercial taking of buffalo fish from Lake Dardanelle and the FSAR l
estimate on poundage is similar to that provided to the NRC inspector
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The licensee did not know for
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certain if the sampling of the catfish would be representative of the exposure pathway involving the buffalo fish.
This is considered an o3en iten pending licensee evaluation of the adequacy of the sampling for tie fish exposure pathway involving bottom feeders-(313;368/8724-03).
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The NRC inspector discussed with licensee representatives the initial
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sampling and analyses of the onsite sanitary system sand-filter beds in
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l August 1987 (not part of the TS environmental sampling program) anri the l
identification of 2.32E-07 pCi/cc cesium-137 and 1.1E-08 pCi/cc iodine-131 l
concentrations in the samples.
Based on the results of the initial i
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campling, the licensee implemented a weekly sampling and analysis of the j
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filter beds to further assess the situati;;t The licensee believes, which
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is yet to be substantiated, that the iodine-131 was the result of an
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employee using the AN0 sanitary facilities after receiving iodine-131 during a medical diagnostic evaluation.
The licensee performed followup
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analyses of samples obtained from the offsite supply location of the
filter sand (washed Arkansas Rivar sand).
The results of these offsite
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samples did not indicate any radioactive concentrations above normal background levels.
The NRC inspector discussed with the licensee the scheduled followup activities and the preparation of a report summarizing the licensee's finding regerding this event.
This will be considered an open item penuing completion of the licensee's evaluation of this event (313;368/8724-04).
l During a review of the licensee's environmental radiation monitoring
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program for ANO Units 1 & 2, the NRC inspector determined that the I
licensee had changed, in late 1986, from using lithium-flouride (Harshaw type) thermoluminescence dosimeters (TL0s) to a four elems.nt,
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2 lithium-borate and 2 calcium-sulfate, (Panasonic Model 802) type TLO.
This is the same TLD that is used for the licensee's inplant personnel
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radiation exposure control program.
The new TLDs are processed and l
qualified in accordance with National Voluntary Laboratory Accreditation
Program for personnel dosimetry processors and industry standard ANSI N13.11, " Personnel Dosimetry Performance Criteria for Testing,"
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criteria.
The NRC ' ins;)ector disemed with the licerree's replasentatives the apparent lack of validation of the Panasonic TLDs ability to tMitfy the testing criteria of ANS1 f64'i-195, " Performance Tosting and
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Procedural Specifications for Tt.n (Environmental Applications)," and as u
recommended by the NRC in Regulatory Guide 4.13.
The NRC inspector
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advised the licensee that there were apparent differences in the two industry stnndards, primarily in,the calibration methods used, and performance criteria > values invniving uniforcity and reproducibility of testing results.
This is considered an open item pending the licensee %
evaluation of the suitability of the Panasonic TED and its current
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calibration program for. environmental applications (313:368/8724-05).
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Meteorological Monitoring Program l
L During a review of the licensee's meteorological monitoring program for agreement with NUREG-0737 and RG 1.97 guidelines, the NRC. inspector determined that the licensee's calibration program did not evaluate rotating sensors (wind direction and wind speed) starting threshold torque which would give an indicatien of potential bearing problems.
The NRC inspector also noted that the licensee calibrates wind speed sensors in the range of approximately 26 miles per hour (mph) to 88 mph.
Since low wind speeds have snali dilution characteristics, it is necessary to know the wind speed in the 1 to 10 mph range for dose assessment purposes.
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Unit 1 & 2 FSARs show that historically the wind speeds at the ANO site are below 10 mph for approximately 75 percent of the time.
The NRC
inspector considers the current calibration of the wind speed sensors i
inappropriate considering the importance low wind speeds play in assessing atmospheric diffusion.
The NRC inspector discussed with the licensee the i
recommendations contained in U.S. Environmental Protection Agencies
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Quality Assurance Handbook for Air Pollution Measuremer.t System, EPA-600/4-82-060 (February 83) concerning calibration'and preventative maintenance of meteorological monitoring systems.
The above concerns are considered an open item pending licensee's review of the meteorological monitoring system calibration program (313;368/8724-06).
The NRC inspector also discussed with the licensee the fact that the meteorological instrumentation (vendor type and model) referenced in s
Section 2.3.3.4 of the Unit-2 FSAR is not the instrumentation currently
installed on the meteo1ological tower.
This concern is considered an open item pending licensee issuance of a change to the FSAR to correct the
discrepancy (368/8724-07).
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Environmental-Sample Analysis Procedures l
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The NRC inspector discussed with the licensee the apparent lack of ANO
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oversight concerning offsite analytical procedures used in performance of-
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AN0 TS environmental surveillance.
These surveillance / analyses are performed at the Little Rock Environmental Laboratory.
The Analytical
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Services Group procedures are provided peer, senior management, and
quality assurance review by the AP&L staff in the Little Rock General l
Office per Technical Analysis Section (TAS) Procedure TA-100, i
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" Administrative-Control of Technical Analysis Procedures." The NRC-inspector,peinted out to licensee representatives the fact that the site
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Plant Safety Committee (PSC) had not reviewed the analytical procedures or i
the administrative pro:edures used by the offsite group to comply w'ith AN3 TS surveillance.
The licensee indicated that currently a project was being conducted to identify those activities performed offsite that the PSC may want to evaluate for inclusion into the scope of the PSC charter.
The licensee noted that the corporate Safety, Review Committee and the site
Quality Assurance Department routinely audit TAS activities associated
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with the radiological environmental numbering program.
The NRC determined that the TAS activities / procedure reviews had not been included for l
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This is considered an open item pending licensee completion of an evaluation for including TAS activities and analytical procedures into the scope of the PSC charter (313;368/8724-08).
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Qitinterview The NRC inspector met with the NRC resident inspector and licensee representatives denoted,in paragraph 1 on September 11, 1987, and summarized the scope and findings of the inspection as presented in this j
report.
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