IR 05000313/1988018

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Insp Repts 50-313/88-18 & 50-368/88-18 on 880523-27.No Violations or Deviations Noted.Major Areas Inspected: Licensee Radiation Protection Activities Associated W/ Radioactive Matl Transportation & Low Level Radwaste Mgt
ML20150B601
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 06/24/1988
From: Baer R, Chaney H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20150B582 List:
References
50-313-88-18, 50-368-88-18, IEB-79-19, NUDOCS 8807120084
Download: ML20150B601 (8)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-313/TC 'l Operating Licenses: DPR-51 50-368/8o-18 NPF-6 Dockets:

50-313 50-368 Licensee:

Arkar.sas Power & Light Company (AP&L)

P.O. Box 551 Little Rock, Arkansas 72203 Facility Nam (.

iansas Nuclear One,AN0), Units 1 & 2 Inspection At:

ANO site, Russellville, Pope County, Arkansas Inspection Conducted:

May 23-27, 1988 Inspector:

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f H.D.Chaney,'RadiationSpecialistfFacilities DaU

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Radiological Protection Section Approved:

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R/ E. Efaer, Chief, Facilities Radiological

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Da'te Protection Section Inspection Summary Inspection Conducted May 23-27, 1988 (Report 50-313/88-18; 50-368/88-18)

Areas Inspected:

Routine, unannounced inspection of the licensee's radiation protection activities associated with radioactive material transportation, icw level solid radioactive waste management, and gaseous and liquid radioactive waste releases.

Results: Within +,he areas inspected, no violations or deviations were identified.

8807120084 88070S DR ADOCK 05000313 PNU

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-2-DETAILS,

1.

Persons Contacted AP&L-

  • J. Levine,' Executive Director for Nuclaar' Operations '

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  • D. Akins,~ Radioactive Waste (Radwaste) Supervisor
  • T. Baker, Technical Support Manager.
  • E. Bickel, Health Physics (HP) Superintendent
  • E. Ewing, General Plant Manager,. Plant Support
  • L. Humphrey, General Manager, Nuclear Quality.
  • D. Lomax, Plant Licensing Supervisor
  • P. Michalk, Licensing Specialist
  • J. Vandergrift, Operations Manager Others
  • W. Johnson, Senior NRC Resident Inspector
  • Denotes those present at'the exit interview on May 27, 1988.

The NRC inspector also contacted other licensee personnel including reactor operators and waste control operators.

2.

Inspector Observations The following is an observation that the-NRC inspector discussed with the licensee during the exit interview on May 27, 1988.. Observations are not violations, deviations, unresolved items, or open items.

This observation was identified-for licensee consideration for program' improvement, but the observation has no specific regulatory requirement. -The licensee stated that the observation would be reviewed.

  • Use of Hich Sensitivity Personnel Contamination Monitors - The licensee-coes not utilize ghi h sensitivity personnel monitors at the exits from radiological work areas in the new or old radioactive waste storage buildings.

3.

Followup on Previously Identi'ied Inspection Findings (0 pen) Violation (368/8706-02):

Failure to Monitor Gaseous Effluents - This item involved the failure of the auxiliary gaseous effluent sampling system to. collect a representative sample of the

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effluent.

This item remains open pending resolution of Audit-QAP-9-87-findings.

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-(0 pen) Deviat'on (368/8706-03):

Failure.to Install, Calibratecand-Operate Radiological Monitoring Systems - This item involved the failure to _ install radiological monitoring equipment in the radioactive waste storage building.. This item remains open pending' resolution of-Audit QAP-9-87. findings.

(0 pen) Open Item (313/8706-04 and 368/8706-04):

Radioactive Waste -(RW)

Organization - This item.' involved the lack of formally defining

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reportability for the RW organization _in Technical Specifications (TS) or safety analysis reports. ~This item remains open pending resolution of TS~

-change requests.

4.

Organization and Management-Controls - Transportation /Radwaste (83522/83722)

-The NRC inspector inspected the licensee's staff assignments including:

organization, assignment of responsibilities, authorities, staffing, identification and correction of problems, audits and surveillances, communication to employees, documentation and implementation relating to

radioactive effluents and solid wastes,-and the transportation of radioactive materials to determine adherence to commitments contained in Section 11 of the Updated Safety Analysis Report (USAR) for Units 1 and 2 t

and the reply to NRC Bulletin 79-19 and the requirements in Units'1 and 2 TS 6.2.

The NRC inspector reviewed the licensee's organization responsible for management of solid radioactive waste processing and transportation of radioactive material (RAM).

The licensee's lack of an accurate organization chart in either the TS or the-USAR that depicts the Radioactive Waste Group's interface with other site organizations was previously discussed in NRC Inspection Report 50-313/87-06; 50-368/87-06, and is being tracked as Open Items 313/8706-04.and 368/8706-04.

The NRC inspector noted that the licensee had changed several titles of personnel within the Radwaste Group and added the position of an HP. supervisor to the group.

Since the licensee is an*'

'pating NRC approval to remove the-l TS 6.2 organization charts' from all um TS, these open items will be further reviewed during a future inspection.

The NRC inspector reviewed the_ licensee's senior management policies'and implementing procedures for control of low-level radioactive waste (LLRW)

processing and transportation of RAM (AN0 Procedure Series 1603.XXX)

including the NRC approved Process Control Program-(Procedure 1012.003),

field quality control. activities (Procedure 1000.23), and quality assurance for transportation activities (NRC approved program, Docket 71-0341).

The NRC inspector reviewed the licensee's audit progran including current and planned audits for LLRW and RAM transportation activities.

The following audits and surveillances were reviewed:

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-4-Surveillance 88-087, Radioactive Material Shipments Surveillance 87-073, TS 4.3.1/ Procedure 2304.37 Surveillance 87 056, orocess Monitor System Calibration Surveillance 87-051, GERM Channel Test Audit QAP-18H-87, Inplace Filter and Charcoal Leak Tests Audit QAP-28-88, Little Rock General Office Technical Analysis Section Activities (Environmental)

Audit QAP-9-87, Design Control (LLRW Storage Building)

The licensee's audits were found to be comprehensive and included an-adequate amount of performance based objectives.

Due to the deficiencies / findings identified in QAP-9-87 (concerning the installation of the effluent and process monitors in the LLRW Storage Building /8706-03

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Violation 368/8706-02 (monitoring of effluents) and Deviation 368 (radiological monitoring systems operation) referenced in NRC Inspection Report 50-368/87-06 will not be closed out until the licensee has resolved the similar audit findings of QAP-9-87.

No violations or deviations were identified.

4.

Training and Qualifications - Transportation /Radwaste (83523/83723)

The NRC inspector inspected the licensee's training program including adequacy of training, employee knowledge, qualification requirements, positior, descriptions, apprentice program for radwaste halper/HP technician, contract technician screening and training, lhP0-accreditation, audits, training not covered by INP0 accreuitation to determine agreement with commitments in Units 1 and 2 USARs and the reply to NRC Bulletin 79-19 and compliance with the requirements of Units 1 and 2 TS 6.3 and 6.4.

The NRC inspector observed work practices and interviewed Radwaste Group personnel.

The licensee's INP0 accredited HP/RW training program, which radwaste technicians participate in, training lesson plans, and requalification tests were reviewed.

The licensee's yearly requalificccion program for personnel involved in radwaste processing and transportation activities was reviewed.

No violations or deviations were identified.

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5.

Solid Radioactive Waste (84522/84722)

The NRC inspector inspected the licensee's program for the control, classification, characterization, and shipment of low-level radioactive waste to determine compliance with the commitments contained in Section 11

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of Units 1 and 2 USAR, and the requirements contained in Unit 1 TS 4.29.4 uand Unit 2 TS 3.11.4, 10 CFR Parts 20.301, 20.311, 61.55, and 61.56, and the recommendations of NRC' Branch Technical Position papers'on LLRW j

classification and waste form.

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The NRC inspector reviewed the licensee's computerized program for management of waste processing-and packaging activities.

The. licensee's

annual evaluation of. waste streams and development of isotope correlation factors was reviewed.

The licensee's LLRW characterization and

classification program is well documented (Procedure 1603.008).

The NRC

inspector reviewed the: licensee's processes for dewatering of filters and i

l resins.

The licensee has implemented a comprehensive chemical control-program so that a transition to high integri_ty polyethylene containers for waste burial can be made.

The NRC inspector noted that the licensee is currently shipping dry compactible and noncompactible radwaste to vendors-

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for additional (super) compaction and segregation. These out-of-state vendors possess agreement state and NRC (if required) licenses.

The licensee is currently planning to test the feasibility of shipping J

radwaste for burial using a combination of truck-trailer and-railcar-trailer routing.

The NRC inspector discussed with the licensee-l the pertinent aspects of 49 CFR Part 174 concerning shipment of trailers

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containing radioactive materials by rail.

The NRC inspector reviewed the licensee's records for LLRW shippad since

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1985.

The following tabulation shows the total volume of LLRW shipped for 1985-87.

Volume Shipped (Cubic feet)

Year Goal Actual Curie Content 1985 30,000 24,300 1,750.0 1986 21,000 4,200 218.3-1 1987 8,200 18,400*

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  • This figure includes a carryover of approximately 14,600 cubic feet from the 1986 year and was part of a planned reduction in long-term stored LLRW due to economic forecasts involving radwaste burial charges.

No violations or deviations were identified.

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Review of Periodic and Special Reports (90713)

The NRC inspector inspected the licensee's semiannual effluent reports for 1986-87 for compliance with the requirements of Unit 1 TS 6.12.2.6 and Unit 2 TS 6.9.3.5, and the recommendations of Regulatory Guide (RG) 1.21.

The NRC inspector noted during a review of the licensee's shipment records and data on waste stipments that the 1987 semiannual effluent and-waste report data concerning volume of vaste shipped and whether or not any

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spent fuel had been shipped were in error.

The licensee stated that they l

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-6-had already identified the problem as_ occurring in'the transfer of radwaste disposal data from the Radwaste Group to'the group (Radicchemistry) that incorporates the data into the RG 1.21 report.

A revision to the two semiannual reports for the year 1987.was being prepared.

The-NRC inspector determined that TS 6.9.3.5 and RG 1.21~do not

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fully explain the type of data required when some of the radwaste shipments are composed.of RAM to waste; processors and the final volume of radwaste following decontamination,'. reclamation, and supercompacting being shipped to burial sites is unknown or could be considerably less-(50 percent or more) than that shipped. 'The-licensee was also confused over-the inclusion of a spent fuel shipment into the RG 1.21 report when they (licensee) were not the "Shipper of. Record." Approximately six spent fuel pins were shipped to the Babcock'and Wilcox plant for inspection by the Department of Energy.

No other problems were identified with current or past semiannual efflisent reports.

This will be considered an Open Item (313/8818-01; 368/8818-01) pending licensee action-to. clarify radwaste disposal data requirement for the semiannual effluent reports and submittal of revised reports for.1987.-

No violations or deviations were identified.

7.

Transportation (86721/86740)-

The NRC inspector inspected the licensee's program for transportation of RAM, spent fuel, procurement of packaging and evaluation of packaging, preparation of packages for shipment, and receipt of RAM for compliance with the requirements of 10 CFR Part 71 and Department of Transportation regulations (49 CFR) incorporated by 10 CFR Part 71.

The NRC inspector reviewed for completeness RAM shipment lreco'rds for the period 1987 through May 24, 1988.

The licensee's authority to -utilize specific shipping packages was verified.

The NRC inspector reviewed the documentation, including advanced notification of the NRC-and: state authorities, for a spent fuel shipment conducted by the 00E in July 1987 from ANO.

The NRC inspector noted that the licensee routinely used extensive checkoff lists for accomplishing shipments of RAM.

The NRC inspector discussed with the licensee the apparent generic problem with swing bolt securing devices on cargo containers (sea / land) with removable tops.in that, when the tops are compressed during lashing-down of the containers on trailers, some of the swing bolts lose their hold on the lid and fall away.

The containers are designed for utilization of another type of hold down device other than cargo straps.

The licensee was aware of the problem and routinely reinspects the hold down bolts and verifies tension prior to the contairer's departure from ANO.

It is conceivable, if retensioning is not performed, that all hold down bolts could come loose during transport.

The licensee / vendor uses these packages as "strong-tight: containers" for shipment of low specific activity (LSA) noncompactible (solid) RAM in accordance with the requirements of 49 CFR Part 173.425.

This particular shipment was

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-7-destined for the ALARON Company in Wampum, Pennsylvania, a radwaste recycler and metals salvage operation.

Mr. J. White, NRC Region I Nuclear Materials Safety Branch, was informed of the inspector's concern.

The licensee had not experienced any transportation incidents which caused a reduction in the effectiveness of packaging since the previous inspection.

No violations or deviations were identified.

8.

Liquids and Liquid Wastes (84523/84723)

The NRC inspector inspected the licensee's program for control, processing and discharge of radioactive liquid wastes (RLW) to determine agreement with the commitments contained in Section 11 of Units 1 and 2 USAR, ano compliance with the requirements of Unit 2 TSs 3/4.11.1, 3.11.1.1, 3.11.1.3, 3.11.1.4, and 3.3.3.10.

The NRC inspector reviewed the licensee's program for controlling discharges of RLW including discharge permits, valve lineups, tank recirculation, sampling and analysis of liquids, and the verification of discharge isolation valve operation upon receipt of a high activity signal.

Reactor control room readouts of proces, monitors were observed.

Discharge permits (Procedure 2104.14) for Unit 2 releases conducted in 1988 (47) were reviewed for adequacy as were selected discharge permits of the 165 releases of RLW from Unit 1.

The licensee's calibration and periodic channel test of effluent discharge control monitors were reviewed for adequacy (Procedures 1304.026, 1304.027, 2304.026, and 2304.027).

The NRC inspectr* also observed a planned RLW release conducted by Unit 2 personnel involving the Boric Acid Condensate System.

No violations or deviations were identified.

9.

G:.seous % ste System (84724)

The NRC inspector inspected the licensee's program for control of radioactive gaseous effluent releases to determine compliance with the requirements of Unit 1 TS 4.29.2 and Unit 2 TS 3.11.2.1.

The NRC inspector reviewed the licensee's documented program for control of waste gas releases to verify that proper sampling and analysis are provided, dose rates in unrestricted areas do not exceed the TS limits, and that release permits are adequate to control gaseous effluent releases.

The NRC inspector also reviewed the licensee's audits /

surveillances of gaseous effluent monitor calibrations for Unit 2 per TS 4.3.3.9 and the control room in place filter and charcoal testing per TS 4.7.6.1.2.

The following procedures were reviewed:

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-8-2304.027, "Process Rad Monitoring System Calibration" (Unit 2)

1304.077, "Process Rad Monitoring System Calibration" (Unit 1)

i 2104.007, "Control Room Emergency AC Ventilation" 1802.006, "Inplace Leak Testing Ventilati;n Systems Containing HEPA and Charcoal Filters" 2304.006, "Gaseous Process Rad Monitoring System Calibration" 2607.018, "Sampling Waste Gas Decay Tanks, Surge Tank, and Volume Control.ank Gas Space on Unit 2" No violations or deviations were identified.

10.

Exit Interview The NRC inspector met with licensee representatives identifiec in paragraph 1 at the conclusion of the inspection on May 27, 1981.

The NRC inspector summarized the scope and findings of the inspection.