IR 05000313/1997009

Insp Repts 50-313/97-09 & 50-368/97-09 on 970224-27.No Violations Noted.Major Areas Inspected:Implementation of Solid,Radwaste Mgt & Radioactive Matls Transportation Programs,Training,Qa Oversight & Procedural Guidance

ML20140B966
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140B958	List: IR 05000313/1997009 ML20140B952
References
50-313-97-09, 50-313-97-9, 50-368-97-09, 50-368-97-9, NUDOCS 9704010551
Download: ML20140B966 (12)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

. REGION IV

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Docket Nos.: 50-313 50-368

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License Nos.: DPR-51

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NPF-6 Report No.: 50-313/97-09  ;

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a 50-368/97-09

Licensee

Entergy Operations, In Facility: Arkansas Nuclear One, Units 1 and 2

Location: Junction of Hwy. 64W and Hwy.333 South

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Russellville, Arkansas Dates: February 24-27, 1997

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Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist j Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch

Division of Reactor Safety

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Attachment: Supplemental Information

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EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 l NRC Inspection Report 50-313/97-09; 50-368/97-09

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l This announced, routine inspection reviewed the implementation of the solid, radioactive ,

I waste management and the radioactive materials transportation programs. Training, j quality assurance oversight, and procedural guidance were also reviewe i Plant Suocort l

l * The solid radioactive waste management program worked well to reduce the volume i of solid radioactive waste generated and to maintain accountability for containers of

radioactive waste. Waste stream sampling met procedural requirements l (Section R1.1).

• The radioactive material transportation program and the revisions to the

! transportation regulations were properly implemented; however, personnel error i

related to the use of computer software was a potential weak area of the program l

(Section R1.2).

* Transportation procedures provided adequate guidance. However, the solid waste j, management procedures provided little guidance related to radioactive waste stream i sampling. The material control procedure needed additional guidance to prevent the i release of licensed material (Section R3).

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! * Appropriate training was provided to the individuals responsible for the preparation

of radioactive shipments (Section R5).

1 1 * Oversight of the solid radioactive waste and radioactive material transportation l programs by quality assurance was adequate (Section R7).

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j Reoort Details I

l Ill. Enaineerina l i E2 Engineering Support of Facilities and Equipment I i

A recent discovery of a licensee operating their facility in a manner contrary to the l 1, Updated Final Safety Analysis Report description highlighted the need for a special j

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focused review that compares plant practices, procedures, and/or parameters to the l l

Updated Final Safety Analysis Report description. While performing the inspection l j discussed in this report, the inspector reviewed the Unit 1 Safety Analysis Report,

Section 11.1.3.3 and Unit 2 Safety Analysis Report, Section 11.5. The inspector

] verified that the Updated Final Safety Analysis Report wording was consistent with i the observed plant practices, procedures, and/or parameters.

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$ IV. Plant Support i

i R1 Radiological Protection and Chemistry Controls i

R Solid Radioactive Waste Manaaement

, Inspection Scoce 86750 l

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The inspector interviewed the radwaste supervisor and reviewed the following activities and elements related to solid radioactive waste management:

i j * Container storage and labeling j * Container accountability i * Waste stream sampling results

! * Waste classification j * Procedures listed in attachment l

• Annual effluent and solid waste reports i

' Observations and Findinas

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j The volume of dry, compressible waste decreased from 134 cubic meters in 1994 l

, to 55 cubic meters in 1995 and to 11 cubic meters in 1996. The volumes of spent 1 i resins and filters also decrease ;

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Through the use of television cameras mounted in the high level radioactive waste i

, storage building, the inspector selected containers and asked licensee j

! representatives to identify the containers and match them to records in I accountability logs. The inspector cross checked the licensee's system by selecting

] different containers from the logs and asking the licensee representatives to verify

the presence of the containers by use of the television cameras. The licensee's

, representatives successfully performed both activities, and the inspector concluded j that the licensee's radioactive waste container accountability system worked

appropriately.

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In order to classify radioactive waste for burial in accordance with the requirements ,

i of 10 CFR 61.55, the licensee used a program modeled after one described in the l Branch Technical Position on Waste Characterization. The program required that the source of radioactive waste be identified and sampled. Licensee personr.el -

identified five radioactive waste streams as being representative of waste generated i at the facility. The waste streams were: primary resins, secondary resins, spent i filters, dry activated waste, and oily radioactive waste. Procedure 1601.504,

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" Curie Content of Radioactive Material Containers," Revision 0, required that resins j be sampled and analyzed during each resin transfer. All other waste streams were j required to be sampled and analyzed annuall l

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The inspector reviewed records of waste stream sampling and analysis and noted that all waste streams were sampled on May 8,1995 and December 20,1996.

j The samples were sent to a vendor laboratory for analysis. Analysis results in each case were reported approximately one month later. Because the interval in waste stream sampling was more than 17 months, the inspector inquired about the licensee's definition of " annually." The licensee had no written definition of i annually, other than in the site's technical specifications. Technical ,

j Specification 4.0.5 defined annually as meaning 366 days. However, licensee's representatives stated that, for tests or surveillances not required by a Technical

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j Specification, they interpreted annually as meaning once per calendar year. The

] inspector acknowledged that the licensee complied with the procedural requirement

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l l The licensee used a vendor supplied computer code to identify the proper waste

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classification. No problems were identified with the classification of radioactive l waste for burial.

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i j Conclusions t-

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The solid radioactive waste management program reduced the volume of solid

radioactive waste generated and maintained accountability for containers of l radioactive waste. Waste stream sampling met procedural requirement ,

t l l R1.2 Transoortation of Radioactive Materials and Radioactive Waste i j Inspection Scoce (86750 and Tl2515/133)

l i The inspector interviewed radioactive waste group personnel and reviewed the following:

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j * Shipping documentation (April 1996 to February 1997)

* Shipping procedures identified in attachment l

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-5-b. Observations and Findinas No shipments were made during the week of inspection; therefore, no observations of actual shipment preparation were possibl The licensee had made shipments of both radioactive materials and radioactive waste. No shipments using the new category for surface contaminated objects had been made. No shipment required Type B packages. Shipments of waste typically went to a vendor for volume reduction before ultimate waste burial. Manifests were provided in accordance with 10 CFR 20.2006 for waste shipment A vendor supplied computer code was used to determine proper radioactive material transportation categories, shipping packages, and labeling. Procedures for manual methods were available as a backup. The inspector r9 viewed the isotope library file of the computer code and confirmed that the latest A, and A 2values for selected isotopes, from 49 CFR 173.435, were use While reviewing shipping documentation, the inspector noted that contents of some shipments, supposedly derived using the same waste stream analysis data base, ranked the isotopes present in the package contents in different orders of abundance. Shipment 7-96 contained trash; Shipment 16-96 contained valves and contamination from the plant. According to licensee representatives, both shipments should have relied on information from the dry activated waste stream data base in the computer code, and documentation for both shipments should have shown the same radioisotope as most abundan Licensee representatives reviewed the matter and determined that, for Shipment 16-96, the incorrect data base was selected by the individual operating the computer code. The correct data base was selected and the computer operation was performed again. The correction did not result in the identification of a different shipping category. After the use of the correct information, the shipment remained categorized as a limit'ed quantity shipment. Nevertheless, this example demonstrated a potential weak area, since the operation of the computer code was central to the licensee's trancportation progra The radioactive waste group met and discussed the inspector's observation to ensure all members understood the importance of carefully selecting the proper computer code inputs. Additionally, the radioactive waste group planned to delete outdated and unnecessary sample results from the data bas No other problems related to the selection of transportation category, packaging, package labeling, or shipping documentation contents were identifie l The inspector selected shipment consignees and verified the licensee maintained I current copies of the consignees radioactive materiallicenses on fil i

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-6-c. Conclusion The radioactive ruterial trr%portation program and the revisions to the transportation regt le%ns were properly implemented; however, personnel error related to the u'O af computer software was a potential weak area of the progra R2 Status of Facilities and Equipment The inspector toured the radwaste building and determined that the facility was as described in the safety analysis reports for both units (Section E2).

R3 Procedures and Documentation

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a. Inspection Scone (86750 and Tl2515/133)

The inspector reviewed various procedures used to implement the waste stream

sampling and analyses, transportation, and release program b. Observations and Findina

Waste Stream Samolina and Analyses:

, According to the radioactive waste group supervisor, the only guidance provided for radioactive waste stream sampling was in Procedure 1601.504, Curie Content of

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Radioactive Material Containers," Revision O. Section 5.1 of the procedure included only the waste stream sampling frequency requirement, as discussed in

Section R1.1. No other guidance or acceptance criteria was provided for sampling waste streams or analyzing the result The licensee sent waste stream samples to a vendor for analysis because the counting facilities on site were unable to analyze for allisotopes for which

! information was required by 10 CFR 61.55. However, Proceduro 1001.504 made no reference to sending waste stream samples to a vendor laboratory. Additionally, there was no guidance as to expectations for updating the computer program data with new waste stream sample analysis results. There was no guidance for updating the scaling factors used to correlate nuclides that were difficult to measure with nuclides that were easy to measure. The inspector confirrned that the data base and scaling factor were updated; however, this was done because of the personal knowledge and initiative of the technician Transoortation:

The licensee used the same basic transportation procedure as the other Entergy sites. The procedure consisted of a flow chart and various checklists as attachments. The flow chart indicated the order in which to perform the major steps in preparing radioactive materials or radioactive waste for shipment. The

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steps referenced regulatory requirements. The attachments included stepwise

instructions and additional regulatory references, specific to the different i

transportation categories. The inspector concluded that the procedure provided adequate guidanc Material Releases:

l Procedure 1012, " Radioactive Material Control," Revision 4, included instruction that must be followed before items and materials could be released from the licensee's control. Section 6.3.9 of the procedure states that material can be " free i released" if it were surveyed with a RM-14/HP-210 and the results of a direct frisk l were less than 100 corrected counts per minute or if the total activity were less ]

than 5,000 disintegrations per minute as measured by an automatic monito )<

The inspector concluded that the literalinterpretation of the guidance of this l procedure was that it was permissible to release items with radioactive contamination levels measuring 99 counts per minute (or 990 disintegrations per minute, assuming a 10 percent instrument efficiency) above background levels if one type of instrument is used, or a total activity of 4,999 disintegrations per minute could be released if another method was used if such releases occurred,

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they would be in violation of 10 CFR 20.200 Information Notice 95-92, " Surveys of Waste Before Disposal From Nuclear Reactor Facilities," addressed this issue and reiterated that no radioactive material can be released, except as authorized in 10 CFR Part 20, Subpart K. In practice, no (licensed) radioactive material means no detectable radioactive material. Although l sometimes misinterpreted, previous discussions in NRC Circular 81-07 did not i establish release limit Licensee representatives acknowledged the inspector's statements concerning j procedural guidance involving waste stream sampling and analyses, and material i releases, but committed to no specific actio l Conclusions l

Transportation procedures provided adequate guidance. However, the solid waste l management procedures provided little guidance related to radioactive waste stream l sampling. The material control procedure needed additional guidance to prevent the release of licensed materia R4 Staff Knowledge and Performance The inspector interviewed members of the radioactive waste group and determined that they were knowledgeable of the revised transportation requirements effective April 1,199 .__ . - _ _-_ . .-. _ _ -

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R5 Staff Training and Qualification  ! Inspection Scope (86750)  ;

I The inspector interviewed training instructors and reviewed the following:

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• Lesson Plans  :

• Attendance lists  !

• Examinations  !

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, Observations and Findinas

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The inspector verified that appropriate individuals were trained on transportation regulation revisions prior to implementation of the new requirements. A vendor ,

provided the training in February 1996. The inspector reviewed the course outline and determined that the training was comprehensiv ,

i Requalification training was provided biennially. The most recent training was  ;

presented in November 1996. The instructor was the radioactive waste superviso ;

The course was audited by training representatives. The inspector reviewed the requalification training lesson plan and concluded that the content was appropriat ;

Radioactive waste staff members also were provided vendor-supplied training, in  !

March 1996, on the operation of the computer code used to classify radioactive j waste for burial and to prepare radioactive material packages for transpor !

I Conclusions Appropriate training was provided to the individuals responsible for the preparation of radioactive shipments.

l R7 Quality Assurance Activities Insoection Scone (86750)

l The inspector interviewed quality assurance personnel and reviewed the following:

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• 1996 quality assurance audit of solid waste management and transportation activities

• Audit checklist for the above audit

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• Audit requirement matrix

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• Audit assignments i

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* Resume of visiting auditor

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• Quality assurance surveillances t  :

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• Commitment change evaluation summary for commitments to NRC j Bulletin 79-19

l Observations and Findings 1  ;

i in its response to NRC Bulletin 79-19, the licensee committed to annual audits of .

transportation activities. On July 25,1996, the licensee requested permission from  !

j the NRC to change the audit frequency to once every 2 years. Permission from the

NRC was received on September 13,1996.

) The inspector reviewed the audit requirements matrix and noted that audits  !

scheduled for 1996,1998, and 2000, each reviewed one-third of the solid

radwaste and transportation program requirements. Even though individual ,

4 elements of the program might go unreviewed for as much as 6 years, the audit  :

l program, as a whole, was determined by the inspector to be comprehensiv ,

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The 1996 quality assurance audit team consisted of six members. Two team  ;

j members had radiation protection experience or experience in shipping radioactive l

} material. These individuals performed the bulk of the auditing activities,

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! From reviews of the audit report and the audit checklist, the inspector determined l'

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The audit report was issued January 16,1997. Responses by the radiation j protection organization to audit findings were not due and; therefore, were not reviewe Only one quality assurance surveillance had been conducted to review

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transportation activities, since the implementation of the revised transportation i regulations. The licensee's position was that oversight of this area was

commensurate with number of problems identified.

I i Conclusions l

Oversight of the solid radioactive waste and radioactive material transportation programs by quality assurance was adequate.

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i j V. Manaaement Meetinas

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X1 Exit Meeting Summary

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j The inspector presented the results of the inspection to members of licensee i management at the conclusion of the inspection on February 27,1997. The

! licensee acknowledged the findings presented and stated that it's definition of

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annually was "once within the calendar year." No proprietary information was I

identified.

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ATTACHMENT 1

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PARTIAL LIST OF PERSONS CONTACTED Licensee i

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l R. Bement, Radiation Protection Manager 4 H. Bishop, Radioactive Waste Supervisor S. Cotton, Training Mancger G. Doran, Health Physics Specialist R. Edington, General Manager D. Fowler, Quality Assurance Supervisor D. Mims, Licensing Director R. Sheide, Licensing Specialist J. Smith, Jr., Radiation Protection Superintendent

. R. Stell, Health Physics Instructor J. Vandergrift, Quality Director NRC K. Kennedy, Senior Resident inspector INSPECTION PROCEDURES USED Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 86750 Solid Waste Management and Transportation of Radioactive Waste ITEMS OPENED, CLOSED, AND DISCUSSED Opened None l Closed None Discussed None

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J-2-LIST OF DOCUMENTS REVIEWED Commitment Change Evaluation Summary P8965 (CMS-97-0014)

Quality Assurance Audit Report QAP-1-96, "Radwaste Management" (10/31-12/12/96)

Quality Assurance Surveillance Report 040-95, "Radwaste Shipment" (11/6/95-2/8/96)

Quality Assurance Surveillance Report 010-96, " Radioactive Material Shipment" (5/9-6/10/96)

Quality Assurance Surveillance Report 015-96, " Radioactive Material Control" (7/25- l 9/4/96)

Radwaste Requalification Lesson Plan, AN10610-094, Revision 1 )

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l 1000.141, " Solid Radioactive Waste Management Process Control Program for !

Arkansas Nuclear One Units 1 and 2," Revision 0 1012.020, " Radioactive Material Control," Revision 4 1601.500, " Radioactive Material Shipment," Revision 1 1601.502, " Radioactive Material Control at Radwaste," Revision 2 1601.503, " Radioactive Material Packaging," Revision 1 1601.504, " Curie Content of Radioactive Material Containers," Revision 0 1601.505, " Processing of Spent Radioactive Resin," Revision 2 1601.506," Radioactive Waste Management Program Surveillances," Revision 1 1601.508, " Segregation of Radioactive Waste," Revision 0 l l

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