IR 05000313/1988024

Insp Repts 50-313/88-24 & 50-368/88-24 on 880718-22.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Radwaste Mgt Programs

ML20151Z592
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/17/1988
From:	Baer R, Nicholas J, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151Z590	List: IR 05000313/1988024 ML20151Z587
References
50-313-88-24, 50-368-88-24, NUDOCS 8808300030
Download: ML20151Z592 (10)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMISSION

REGION IV

l NRC Inspection Report:

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50-313/88-24 Operating Licenses: . OPR-51

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50-368/88-24 NPF-6

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Dockets: 50-313 50-368 Licensee: Arkansas Power & Light Company (AP&L)

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P.O. Box 551 -

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Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One (AN0)

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. Inspection At: AN0 Site, Russellville, Pope County, Arkansas Inspection Conducted: July 18-22, 1988 Inspectors: . P///, /F ff 8. Nicholas, Senior Radiation Specialist Date facilities Radiological Protection Section

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L.T.Ryk Date

] Facil'/gs'ytso,R"adiationSpecialist Radi gical Protection Section  ;

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Approved

M R. E. Baer, Chief, Facilities Radiological c@d7/4S ,

Date Protection Section i

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Inspection Summary

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Inspection Conducted July 18-22, 1988 (Report 50-313/88-24; 50-368/88-24)

Areas Inspected: Routine, unannounced inspection of the licensee's liquid and i gaseous radioactive waste management program Results: Within the areas inspccted, no violations or deviations were identified.

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t 8808300030 880822 PDR ADOCK 05000313 I o PDC

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-2-l l DETAILS Persons Contacteo AP&L

• J. M. Levine, Executive Director, AN0 Site Operations

• T. C. Baker, Technical Support Manager B. L. Bata, Quality Assurance (QA) Engineer D. K. Crabtree, Engineering Program Supervisor

• W. T. Craddock, Acting General Managar, Plant Support C. B. Fite, Operations Trainer, Unit 2 M. E. Frala, Assistant Radiochemistry Supervisor

• R. D. Gillespie, Technical Analysis Superintendent

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• H. Greene, QA Superintendent l *0. C. Harris, Lead Trainer, Chemistry /Padiochemistry J. E. Haynes, Operations Trainer, Unit 1 L. G. Hodges, Training Instructor, Chemistry / Radiochemistry

• 0. B. Lomax, Plant Licensing Supervisor l R. D. McCormick, Nuclear Quality Specialist, Chemistry / Radiochemistry i *W. C. McKelvy, Assistant Radiochemistry Supervisor l *P. L. Michalk, Licensing Specialist O. J. Wagner, QA Engineer H. D. Young, Engineering Technician

• Denotes those present during the exit interview on.luly 22, 1988.

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l NRC Inspectors Observations i l j l The following are observations the NRC inspectors discussed with the l l licensee during the exit interview on July 22, 1988. These observations l are not violations, deviations, unresolved items, or open items. These observations were identified for licensee consideration for program .

improvement, but the observations have no specific regulatory l requirements. The licensee stated that these observations would be evaluated.

l Contractor Audit ?rogram l

l The licensee had not performed a technical analysis audit of the contractor laboratory performing iron-55 analyses. (See paragraph 5.) Semiannual Effluent Release Reports

The licensee had not correlated radiation dose data due to radiological effluents to Technical Specification (TS) requirement (See paragraph 7.)

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3- Organization and Man'agement Controls- (83722/83522) l The NRC inspectors reviewed the licensee's organization, staffing, identification and correction of program weaknesses, audits and app'raisals, communication to' employees, and documentation and implementation of the radioactive waste effluent program (RWEP) to determine adherence to commitments in Chapter 12 of the Unit 1 Updated Safety Analysis Report (USAR) and Chapter 13 of the tenit 2 USAR and the requirements in Section 6.2 of Units 1 and 2 T The NRC inspectors verified that the organizational structure of the ANO ,

radwaste effluents operations section and radiochemie.try section were as defined in the USAR and T The ANO management control procedures.and position descriptions were reviewed for the assignment of responsibilities for the management and implementation of the ANO RWE The NRC inspectors ,

3 verified that the administrative control responsibilities specified in the ANO procedures were being implemente ,

3 The NRC inspectors reviewed the staffing of the radwaste control operators

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section and the radiochemistry section and determined that both sectit ns

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No violations or deviations were identifie . Training and Qualifications (83723/83523)

The NRC inspectors reviewed the licensee's training and qualification program for radiochemistry personnel and nonlicensed waste control operators (WCO) responsible for the RWEP including: education and

, experience, adequacy and quality of training, employee knowledge, j qualificatian requirements, new employees, Institute of Nuclear Power Operations (INPO) accreditation, and audits and appraisals to determine

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adherence to co.:aitments in Chaptcir 12 of the Unit 1 USAR and Chapter 13 i

of the Unit 2 USAR and the requirements in Sections 6.3 and 6.4 of the Units 1 and 2 T The NRC inspectors reviewed the qualifications of selected radiochemistry (

staff and nonlicensed WC0 responsible for the implementation of the RWEP and verified that they met the mqu.ced qualifications specified in the USAR and T It was determined that the licensee had an adequately qualified staf The NRC inspectors reviewed the training programs for radiochemistry personnel and nonlicensed WCO, including a review of task analyses, course descriptions, lesson plans and objectives, training schedules, personnel training records, and qualification cards. The NRC inspectors found that the licensee's training program was being implemented in accordance with .

ANO procedures. It was determir.td that the ANO training programs for chemistry and nonlicensed operators were INPO accredite I f

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-4-The NRC inspectors reviewed individual staff training records and qualification cards for selected radiochemistry personnel and nonlicensed WC0 responsible for performing RWEP activities and verified that they had completed the required training on the Radiological Effluent Technical Specifications (RETS), Offsite Dose Calculation Manual (0DCM), radwaste systems, and liquid and gaseous radioactive waste effluent release procedure No violations or deviations were identifie . Liquids and Liquid Wastes (84723/84523)

The NRC inspectors reviewed the licensee's liquid radioactive waste effluent program including: liquid waste construction and installation; liquid leakage, overflow, and spillage; liquid waste sampling; liquid process and effluent monitors; procedures for liquid waste and effluent systems; reactor coolant and secondary water quality; and audits and appraisals to determine adherence to commitments in Chapter 11 of the Units 1 and 2 USAR and requirements in Sections 3.5.6, 3.25.1, 4.29.1, and 6.14 of the Unit 1 TS and Sections 3/4.3.3.10, 3/4.11.1, and 6.14 of the Unit 2 TS and the ODC The NRC inspectors reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, RWEP operating procedures, offsite dose results from liquid effluents, and functional checks and calibrations of equipment associated with the radioactive liquid waste processing syste The NRC inspectors reviewed current approved revisions of ANO procedures governing the release of liquid radioactive waste. These liquid effluent release procedures provide for the following: sampling of radioactive waste; chemical and radionuclide analyses prior to release; calculation of effluent release rates, effluent radiation monitor setpoints, projected offsite radionuclide concentrations, and offsite doses prior to release; recording effluent dilution parameters during releases; and verifying :

discharge flow rates and effluent volume discharge The NRC inspectors reviewed a representative number of liquid release permits for the period January 1987 through June 1988. It was determined that processing, sampling and analysis, and approval and performance of the releases were conducted in accordance with ANO procedures. Qaantities of radioactive nuclides released in the liquid effluents were within the limits specified in the RETS. Offsite doses had been calculated according 3

to the ODCM and were within the TS limits. Liquid effluent radiation j monitor setpoints were being calculated in accordance with the ODC '

The NRC inspectors determined that a contract had been awarded to Duratek Company to process Unit I liquid radwaste. The contract extends through 198 The Duratek Enhanced Volume Reduction Processing System replaces the Unit 1 radwaste demineralizers during the period of the contrac l l

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-5-The NRC ins'ectors p reviewed procedures ~and selected reactor coolant and secondary water chemistry records for the period January 1987. through :

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June 1988.- The records reviewed indicated that all required sampling and analyses were performed at the frequencies required by the T ,

The NRC inspectors reviewe'dl source' checks, channel function _ tests, calibrations, and setpoint procedures and records for radioactive waste liquid effluent monitors'which showed that the channel-functional checks and calibrations-were being performed at the required frequency'using ,

radioactive standards traceable to the National Bureau of Standards. The NRC inspecto'rs verified that the'radwaste effluent' monitors were operable at the time of the inspection and met TS requirement The NRC inspectors reviewed selected QA audit-and surveillance procedures, ,

audit schedules for 1987 and 1988, and the qualifications of auditors ~.

Selected QA surveillance and QA' audit reports concerning activities performed during 1987 and 1988 in the areas of radiochemistry,_

environmental, and radwaste processing were reviewed for scope to' ensure thoroughness of program evaluation and timely followup.of identified findings. The NRC inspectors found the audit plans, checklists, and ,

surveillances to be comprehensiv The NRC inspectors determined that the licensee was using a contractor laboratory to perform the iron-55 analysis on radioactive liquid waste effluent required by TS. The licensee was'also using a contractor to i perform in place filter testing and laboratory charcoal adsorber analyses t on the station ventilation systems as required by TS. The licensee had ;

performed a QA program audit on the contractor laboratory and had !

evaluated a CASE audit of the contractor performing in place filter '

testing and laboratory analyses on the station ventilation systems and had placed both contractors on the ANO qualified vendor list. The NRC inspectors observed that the licensee had not performed a technical '

analysis audit on the contractor laboratory performing the iron-55 analysis on the radioactive liquid waste effluents. This observation was .

discussed with the licensee during the inspection and at the exit j interview on July 22, 1988. The licensee agreed to evaluate the NRC .

inspectors' concerns dealing with performing a technical analysis QA audit of the contractor laboratory even though the laboratory was not providing '

a safety-related analysis, t

No violations or deviations were identified.

l Gaseous Waste System (84724/84524)

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The NRC inspectors reviewed the licensee's gaseous radioactive waste effluent program including: gaseous waste system construction and installation, gaseous waste sampling, gaseous effluent monitors, ;

procedures for gaseous waste and effluent systems, air cleaning systems, j and audits and appraisals to determine adherence to commitments in l

Chapter 11 of the Units 1 and 2 USAR and requirements in Sections 3.9, !

! 3.13, 3.15, 3.22, 3.25.2, 4.10, 4.11, 4.17, 4.25, 4.29.2, and 6.14 of the l l c l  !

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-6-Unit 1 TS and Sections 3/4.3.3.9, 3/4.7.6, 3/4.9.11, 3/4.11.2, and 6.14 of the Unit 2 TS and the ODC The NRC inspectors reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling _ requirements, surveillance tests, RWEP operating procedures, offsite dose results from gaseous effluents, and functional checks and calibrations of equipment associated with the radioactive gaseous waste processing syste The NRC inspectors reviewed current approved revisions of ANO procedures governing the release of gaseous radioactive waste. These gaseous effluent release procedures provide for: the sampling of gaseous radioactive waste, calculation of projected offsite radionuclide concentrations and doces. calculations and verification of gaseous effluent radiation moa nor setpoints, and verification of discharge flow rates and effluent volume discharge The NRC inspectors 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 1987 through June 1988. It was determined that the gaseous waste releases were being performed according to ANO procedures and the quantities of 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 inspectors 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 NRC inspectors determined that no design changes had been made to the gaseous radwaste management system since the previous NRC inspection in January 198 The NRC inspectors reviewed source checks, channel functional tests, calibrations, and setpoint procedures and records for gaseous radioactive waste effluent monitors, and verified that th? frequency of the various checks and calibrations met TS requirements. The monitor calibrations and setpoint determinations were verified to have been performed according to approved procedure The NRC inspectors reviewed the licensee's procedures and surveillance ,

tests for maintenance and testing of air cleaning systems which contain high efficiency particulate air (HEPA) filters and activated charcoal adsorbers. The NRC inspectors verified that the licensee's procedures and surveillance tests provided for the required periodic functional checking of ventilation system components, evaluation of HEPA and activated charcoal adsorbers, tracking of system operating hours, and replacement l and in place filter testing of filter systems. The licensee's l surveillance test results for the period January 1987 through June 1988 l were reviewed and verified to be within TS limits, l i

No violations or deviations were identifie !

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. Reports of Radioactive ~ Effluents The NRC inspectors reviewed the licensee's records and reports concerning l radwaste systems and effluent releases for compliance with the _

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requirements of 10 CFR Part 50.36(a)(2) and Section 6.12.2.6 of the Unit 1 t

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TS and Section 6.9.3 of the Unit 2 T ,

The NRC inspectors reviewed the semiannual effluent release reports for th periods July 1 through December 31, 1986; January 1 through June 30, 1987; -

and July 1 through December 31, 1987. These reports were written in the

, format described in NRC Regulatory Guide 1.21 and contained the

information required by TS. It was noted that the first report filed each year contained a summary of radiation doses due to radiological effluents during the previous calendar year calculated in accordance with the methodology specified in the ODCM. However, it was observed that the radiation doses were not presented in such a' manner as to easily determine compliance with_TS requirements. The licensee had not provided a technical explanation or summary of the data in the semiannual reports in a format which provided a direct correlation to TS requirements. This -

observation wr.s discussed with the licensee during the inspection and at the exit interview on July 22, 1988. The licensee agreed to evaluate the '

NRC inspectors' observation for program improvemen No violations or deviations were identifie . Exit Interview The NRC inspectors met with the licensee representatives denoted in

paragraph 1 at the conclusion of the inspection on July 22, 1988. The NRC inspectors summarized the scope and findings of the inspection and discussed the NRC inspectors' observations. The licensee representatives .

stated at the exit interview that they would evaluate the NRC inspectors' !

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observations and concerns and take necessary corrective action to implement program improvement ,

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ATTACHMENT 1 i

Orkajlpps Nuc1 ear Onr=

NRC Inspection Report 50-313 t< 360/88-24 Documentn Reviewed Ittle Bevtut9a Dein Administrative Procedures 1000.001, Organization and Responsiblities 16 02/27/87 1042.003, Radiochemistry Routine Surveillancu 6 01/13/80 Schedule and Tech. Spec. Surveillance Reporting Ch o m i st r y / Ra_dio_c h em i s t r y Proceduren 1604.001, Gross Alpha Measurement 11 06/25/88 1604.002, Gross Deta and Gamma Spectroscopy 6 04/13/87 Sample Preparation 1604.003, Tritium Sample Preparation 5 04/09/87 1604.004, Li qui d Scintillation Counting For 9 03/26/87 Gross Beta and Tri tium Measurements 1604.009, Radiostrontium Determination 13 02/13/88 1604.014, Reactor Building Purge Analysis 10 01/30/86 1604.015, Analysis of Unit Vent and Condenser 8 06/10/88 Vacuum Punip 1604.016, Analysis of Gasecue Wacte Decay Tanks 6 01/30/86 1604.017, Analysis of Liquid Waste 12 12/23/87 1607.007, Sampling the Laundry Drain Tanks S 04/15/87 1607.008, Sampling the Filtered Waste Monitor 4 06/10/85 Tank (T-21 A/B)

1607.009 Sampling the Treated Wante Monitor 7 04/15/87 Tanks (T-16 A/b>

1607.010, Sampling of the ANO Unit 1 Vent 5 07/20/88

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1607.014, Reactor Du11 ding Purge Sampling 2 01/14/87 Procedure 1607.018, Sampling the Unit 1 Waste Gas Decay 4 01/14/87 Tanks and Surge Tank 1607.024 Unit 1 Dirty Wante Drain Tank O 01/13/88 (T-20 A/D) Sampling Procedure 1607.025, Sampling the Unit 1 Condenser Vacuum 3 11/12/G6 Pump Discharge 1607.027, Sampling of Condensate Pump Effluent 1 03/23/05 1607.02G, Sampling the Unit i Turbine Building 2 04/15/87 Sump, Oily Water Separator, and Neutrali:ing Tank 2607.008, Unit 2 Waste Tank (2T-20 A/B) Sampling 3 06/08/87 Procedure 2607.009, Sampling the Unit 2 Waste Condensate 6 10/02/07 Tanks (2T--21 A and 2T-21B)

2607.010. Sampling the Unit 2 Vents 4 01/14/87 2607.014, Reactor building Purge Sampling 3 01/14/87 Procedure 2607.016, Sampling the Unit 2 Holdup Tanks 2 03/16/85 (2T-12A, B, C, end D)

2607.018, Sampling the Waste Gas Decay Tanks, 5 01/14/87 Surge Tank, and Volume Control Tahk Gas Space on Unit 2 2607.026, Sampling the Regenerative Waste Tanks 3 03/07/85 (2T-92A, D, and C) Oper at i ons Procedures 1104.014, Dirty Liquid Waste and Drain 12 04/30/87 Processing 1104.015, Laundry Waste Processing 9 05/21/87 j 1104.020, Clean Waste System Operation 22 01/27/88 1104.022, Gaseous Radwaste System 20 12/05/07

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1104.033. Reactor Building Ventilation 33 03/11/88 l

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2104.010, Unit 2 Waste Gas Analyzer Operation 9 02/17/88

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2104.014, Liquid Waste Systems Operation 14 11/17/87 2104.022, Gaseous Radwaste System 17 03/11/88 Surveillance Proceduren 1092.081, In-Place Leak Testing of Ventilation O 03/22/88 Systems Containing HEPA and Carbon Filters 1802.001, Interr ogati on of Tech. Spe /21/84 Surveill ance Limi tations, Safety-Related Ventilation Systems Quality Assurance (OA) Surveillances and Audits OA Eurvet11ance Report 87-045, "Stack Flow Instrumentation Calibration," dated June 17, 1987 OA Surveillance Report 87-099, "Penetration Room Ventilation Standby System Monthly Test," dated December 24, 1987 OA Surveillance Report 88-073, "Sampling of the ANO Unit i Vent," dated May 3, 1988 OA Audit Report, QAP-3-87, "Heal th Physics and Radwaste Management,"

performed May 29, 1987 - November 23, 1987 OA Audit Report, OAP-22-87, "Environmental Monitoring," performed September 30, 1987 - December 8, 1987 OA Audit Report, OAP-28-88, "ANO Envirnnmental Monitoring Program,"

performed March 1, 1988 - May 25, 1988 OA Vendor CASE Audit Report, "Nuclear Containment Systems," dated December 5, 1986 [4NO Semiannual Effluent Releace Reports July 1 through December 31, 1986 January 1 through June 30. 1987 July 1 through December 31, 1987 ,

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