IR 05000313/1990023

Insp Repts 50-313/90-23 & 50-368/90-23 on 900716-20.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Waste Mgt & Water Chemistry Programs

ML20059F362
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/23/1990
From:	Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059F347	List: IR 05000313/1990023 ML20059F344
References
50-313-90-23, 50-368-90-23, NUDOCS 9009110188
Download: ML20059F362 (8)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION +

REGION IV ,

NRC Inspection Report: 50-313/90-23 Operating Licenses: OPR-51 50-368/90-23 NPF-6 Dockets: 50-313 7-50-368 -

Licensee: Entergy Operations, In *

P.O. Box 551 #

Little Rock, Arkansas 72203 q Facility Name: Arkansas. Nuclear One (ANO) l

Inspection At: ANO, Russellville, Arkansas

' Inspection Conducted: July 16-20, 1990 Inspector: . /l/ iNf L. TT Ricketson, P.E., Senior Radiation D6te '

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Specialist,. Facilities Radiological

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Protection Section

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Approved: ./[ 16 '[6[lf BI!aine Murray, Chief, Facilittds Radiologicai

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D(te / E Protection Section /

i Inspection Summary

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Inspection Conducted July 16-20,1990 (Report 50-313/90-23: 50-368/90-23) 1 Areas Inspected: Routine, unannounced inspection of the licensee's liquid and

gaseous waste management'and water chemistry program r L Results: Within the areas inspected, no violations or_ deviations were 1. ' identified. The licensee had maintained an adequate' staff of well qualified l personne1 ~ to handle the liquid and gaseous radioactive waste and. water a chemistry control ' programs. Liquid and gaseous release permit programs had been implemented that required appropriate reviews and approvals before

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allowing the. release of radioactive materials. Modifications were made'to the

. gaseous effluent monitors to-improve system reliability.

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The licensee had performed comprehensive QA audits that identified several , ,

problem areas. These problems included a backup gaseous effluent monitor that could not meet the detection limits specified in the Technical Specifications and deficiencies associated with testing the air cleaning systems.. The inspector identified some concerns regarding releases from the turbine building sump and the quality of microfilm record No problems were identified concerning the water chemistry control progra L

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-3-DETAILS Persons Contacted AP&L

• J. Yelverton, Director of Nuclear Operations T. Armstrong, Nuclear Chemist W. Butzlaff, Supervisor, Quality Assurance (QA)

M. Chisum, Systems Operations Manager, Unit 2 J. Douet, Supervisor, QA D. Irving, Systems Operations Manager, Unit 1 J. Jacks, licensing Spec.alist R. Johannes, Acting Plant Manager, Unit 1 D. McEntyre, Nuclear Chemist

• W. McKelvy, Acting Manaaer, Chemistry / Radiochemistry

• J. McWilliams, Executive Assistant

• G. Provencher, Manager, QA

• R. Sessoms. Plant Manager, Central

• Scheide, Licensing Specialist J. Waxinfelter, Instruments and Controls (I&C) Superintendent, Unit 2 T. Wilkens, I&C Supervisor N.R_ * Warren, Senior Resident Inspector R. Haag, Resident Inspector

• Indicates those present at the exit meeting on July 20, 1990. Followup on Licensee Event Reports (LERs)

(Closed) LER (313/90-003-00): Use of Incorrect Instrumentation to Ensure Compliance with Technicc1 Specifications (TS) - The licensee incorrectly assumed that the stack effluent monitor (RE7400) was sensitive enough to ensure that the radioactivity limits in TS 3.5.7 were not exceeded. A Design Engineering evaluation determined that the monitor was not capable of measuring the Xenon 133 equivalent required by the Radiological Effluent Technical Specifications (RETS). An audit performed by the licensee during the first quarter of 1990 identified-that the licensee had not been in compliance with TS requirements since 1985, during those time "

when the stack monitor was used instead of the super particulate iodine noble gas (SPING) monitors to meet TS 3.5.7 requirements. The licensee' evaluation determined that the root cause was a lack of management oversight and involvement. As corrective action, licensee management i notified its staff by memo (dated May 25,1990) that the effluent monitor RE 7400 does not meet the requirement of the TS. The licensee also committed to remove all references to the monitor from operations and chemistry procedures as well as the Offsite Dose Calculations Manual (00CM).

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(Closed) LER (368/90-012-00): Failure to Perform Channel Calibrations of the Radwaste Effluent Line Flow Monitor - As the result of an audit during the first quarter of 1990, the licensee identified that the flow monitor on the liquid radwaste offluent line had not been calibrated during the period January 1,1985, to July 1987. TS 4.3.3.10 requires that a channel calibration be performed every 18 months. The licensee's evaluation determined that the root cause was a deficient process which did not ensure that necessary procedure modifications were performed when TS amendments were issued. As corrective action, the licensee issued a licensing department directive requiring that an information copy of TS amendments be sent to managers to identify any necessary actions,

-including required procedure change., in advance of receiving the TS amendment. The directive also requires, upon receipt of the amendment, that the actions be implemente . Organization and Management Controls The inspector reviewed the licensee's organization and management controls to determine compliance with TS 6.5.2.8 for Units 1 and 2 and commitments in Chapter 12 of the Unit 1 Updated Safety Analysis Report (USAR) and Chapter 13 of thc Unit 2 USA The inspector determined that implementation of the radioactive waste effluent program was a shared responsibility between the operations and radiochemistry groups. The organization of each group was as described in the USA The inspector reviewed the results of the following QA audits:

QAP-17E-90, " Unit 1 Instrumentation Systems" QAP-171-90, " Unit 1 Ventilation" QAP-180-90, " Unit 2 Instrumentation Systems" QAP-28-90, " Environmental Monitoring Program" Audits appeared to be thorough with numerous findings, including: the identification of a stack monitor which did not meet the sensitivity requirements of TS 3.5.7, failure to perform the reactor building purge ;

channel functional test prior to release, lack of documentation of channel l checks for particulate-iodine-noble gas monitors, alarms that do not

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transmit to the control room as stated in the USAR, failure to follow

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testing procedures for the air cleaning systems failure to calibrate filter differential pressure instrumentation, failure to follow sample ,

collection procedures, failure to calibrate tank level instrumentation, !

and failure to calibrate a liquid effluent release flow monitor at the proper frequency. As a result of the findings, the licensee generated the LERs listed in paragraph 2 of this report. Some responses to QA's findings were still forthcoming, since some audits were only conducted recentl >

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Additionally, the audits included many program improvement recommendations !

and observations. The QA representative stated that auditors had varied backgrounds, including operations, chemistry, I&C, and radiati: '

protection, hence the performance-based nature of the audit The licensee performed audits in September 1988 and May 1990 of the offsite vendor which performed iron-55 analysis. The first audit identified deficiencies, which were corrected by the vendor before the second audit, which did not identify further deficiencies. The audits were conducted by an individual with technical knowledge of the subjec No violations or deviations were identifie . Training and Qualifications The inspector reviewed the training and qualifications for '

chemistry / radiochemistry personnel to determine compliance with TS and 6.4 for Units 1 and 2, and the commitments in Chapter 12 of the_ ,

Unit 1, USAR and Chapter 13 of the Unit 2, USAR. All personnel met the '

established qualification '

Chemistry and' radiochemistry have been combined and individuals will be qualified in.both areas. The inspector reviewed examples of tasks performed by the group and a qualification / task matrix and determined that the tasks were performed by qualified individuals. The inspector also observed sampling procedures and determined that they were performed in a i proper manne ,

No violations or deviations were identifie !

5. Liquid and Gaseous Effluents

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The inspector reviewed the licensee's liquid and gaseous radioactiveLwaste ef fluent program to determine compliance with Sections 3.25.1, 3.25.2, ;

4.29.1, 4.29.2, and 4.29.3 of the Unit 1 TS; and Sections 3/4.1 '

ar.d 3/4.11.2 of the Unit 2 TS; and the commitments in Chapter 11 of the

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USAR of Units 1 and :

The inspector reviewed selected liquid and gaseous release permits for '

batch and~ continuous releases for the period January 1 through July 18, 1990, and determined that releases did not exceed regulatory limits. The inspector also verif ted that offsite doses for the releases were calculated in accordance with the ODCM and were within TS limits. The inspector noted that the quality of records on microfilm was poor. The '

licensee's representatives stated that radiochemistry had obtained new computer printers which were to be installed shortly and would improve the quality of the original records and subsequently the copies on microfilm. -

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The inspector'noted that in some cases the radiological analysis of water from the Unit I turbine building sump was not completed before the water was released through the oily-water separator and back into'the service-

. water intake area. Although-sample resuitt indicated that' radioactivity concentrations were typically several ordets of magnitude below regulatory-limits,;the inspector'was initially concerned that this constitute potential pathway for uncontro11~1 release of radioactivity to the

..h , , environment; however, no radioactive material had been released through

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this path. Unit 1 does not currently have a steam generator leakage:

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problem, but'does have some residual contamination frc.y a previous contamination p.roble g Licensee representatives in the radiochemistry group stated that they do f not always receive. notice from the operations group concerning releases 4 from:the tmime building sump far enough in advance to enable them t .. complete nr, chemistry analysas before the release begins. In those 6" cases notea by the inspecht, ue licensee explaine.. that if the water had not been released from tha w9, it would have overflowed onto the turbine 4 building floor. The sump *x aived only drains = from- secondary systems 'and-the drainline in each unit was fitted with a radiation monitor; however, the monitor on Unit 2 had not-yet been accepted by the operations-group as

, operational. _If radiaWn levels in the drainpipe exceed the setpoint fo the monitor. an alarm sounds in the control room, but the' release is not automatically. interrupted. Discussions with licensee ' personnel determined that the cetpoints on the monitors correspond to.0.1 percent.of the regulatory limit and that personnel had been directed to manually stop the release.if.the alarm actuates. However, there was no procedure which addressed such releases, except when there is known steam generator tube -

leakage. The licensee's representatives stated that'they would evaluate .

the process of releasing: water from the sump _ to determine if changes were'

necessar No-violations =or deviations were identifie . Instrumentation The inspector reviewed the licensee's process radiation monitoring g instrumentation and surveillances'for compliance with Sections 3.5.6, 3.5.7,-4.29.1.3, and;4.29.2.3 of the' Unit 1 TS; and Sections 3/4.3. and 3/4.3.3.10 of the~ Unit 2 T The licensee's representatives reported close agreement between the sampling results of-the gaseous effluent SPING monitors and the results of

. grab samples; however, the inspector determined that there had been numerous mechanical reliability problems with the monitors. Licensee s- representatives stated that some of the problems were caused by unfamiliarity with the equipment by I&C personnel and others were caused by component failure. In response to these problems, the vendor presented a 1-week training. course to members of I&C and modified the sampler These actions have resulted in increased ro11 ability of the monitor i

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During Audit QAP-17E-90, the licensee. identified that the.. stack

- monitor-(RE7400)1had been used at times as a Sackup to the SPING monitor to> ensure compliance with TS 3.25.2, when, in fact, it could not meet the

- required sensitivit Licensee response to this finding is documented in

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paragraph 2 of_this repor The' inspector reviewed selected examples of radioactive liquid and gaseous effluent monitoring instrumentation source checks and channel. checks, o calibrations, and tests. All examples were satisfactor '

- No violations or deviations were. identifie . 7.- Water Chemistry

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' The inspectors reviewed selected reactor coolant water chemistry records l for the period June 1 through July 19, :1990, and determined that sampling'

and analysis were-performed as required by Unit 1 TS 3.1.5 and Unit 2

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TS 3/4. No violations or deviations were identifie . -Air Cleanin The inspector reviewed the results of in place tests for the HEPA filters :

and charec31 adsorber unit, and laboratory iocine removal-efficiencies to determine compliance with Sections- 3.13,.3.15, 3.22, 4.10,-4.11, 4.17, and-4.25 of the' Unit 1 TS; and Sections 3/4.7.6:and 3/4.9.11 of the Unit 2 T a n

The inspector-determined that Engineering Services had:the responsibility- '

for in place testing -and employs a vendor to perform the tests. The licensee's Audit QAP-171-90-identified;a number of problems with the:

surveillances associated with the< systems. 'For example, the?1icensee E identified-a procedural violation by the vendor who performed'in place' 1 leak. testing of charcoal'adsorbers'resulting from the vendor's failure.to- !

take the required number of samples. The: audit also identified the lack of regular calibration of filter. differential _ pressure instrumentation on ventilation filtration units and the. failure _to'take the required samples for=offsite-laboratory adsorber efficiency' analyses. Responses to the findings were not due until August 10,s199 !

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~The inspector reviewed selected records'of surveillances performed on the !

control room,.pe.netration room, and fu'ei handling area air cleaning !

systems. A11= surveillances were satisfactor No violations or deviations were identifie ,

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L,, Exit'Meetino:

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.The' inspector. met with the senior residsnt inspector and the licensee's

representatives denoted in paragraph.1.at the conclusion of the inspection-on July 20,1990, and summarized the scope'and findings of-the

inspection

.p as presented.in this report. The licensee did not-identify as proprietary f any of the materials provided to, or reviewed by, the inspector during the y  ; inspectio i

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