ML20197C530
| ML20197C530 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear |
| Issue date: | 09/13/1978 |
| From: | Brown G, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20197C512 | List: |
| References | |
| 50-313-78-14, NUDOCS 7811210121 | |
| Download: ML20197C530 (11) | |
See also: IR 05000313/1978014
Text
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
IE Inspection Report No.
50-313/78-14
License No.
Licensee:
Arkansas Power and Light Company
Docket No.
50-313
Sixth and Pine Streets
Pine Bluff, Arkansas
Facility: Arkansas huclear One, Unit 1 (ANO-1)
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Location:
Russellville, Arkansas
Inspection Conducted: August 14-18, 1978
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Inspector:
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81aihe' Murray,' Radiation 1 Specialist
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Approved by:
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"G1efi D. Brown,' Chi'ef, Fue'l Facility and
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Material Safety Branch
Inspection Summary
Inspection on August 14-18, 1978 (Report No. 50-313/78-14)
Areas Inspected:
Routine unannounced inspection of the licensee's:
(1)
' radiation protection; (2) analytical measurements programs including the
radiation protection organization; licensee audits; radiological protection
procedures; instruments and equipment; exposure control; posting, labeling
and control; surveys; radioactive shipments; notification and reports; and
confirmatory measurement results. The inspection involved thirty-four
(34) on-site hours by one NRC inspector.
Results:
Four (4) items of noncompliance (Infractions:
(1) failure to
control high radiation areas.
See paragraph 9.a; (2) improper radioactive
shipment.
See paragraph 12.
Deficiencies:
(1) failure to label radio-
active material container.
See paragraph 9.b; (2) failure to furnish
termination exposure reports.
See paragraph 11.) and one unresolved item
(Seeparagraph15.)wereidentified.
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DETAILS
1.
Persons Contacted (AP&L)
- L. Alexander, QA Supervisor
J. L. Bates, Radiochemistry Supervisor
- R. G. Carrol, Health Physics Supervisor
- C. H. Halbert, Technical Support Engineer
- G.
H. Miller, Plant Manager
- M. M. Nichols, Assistant Health Physics Supervisor
- C. S. Petzel, Licensing
D. Trimble. Training Coordinator
- Denotes those present during exit interview.
2.
Scope of Inspection
The purpose of this inspection was to review the licensee's radiation
protection and analytical measurement programs for the period April 1,
1978, through August 16, 1978.
3.
Radiation Protection Organization
The inspector reviewed the licensee's radiation protection organization
to determine compliance the Technical Specifications and FSAR commitments.
Three (3) Health Physics Technicians have been recently added to the
staff. The present staff consists of 10 technicians to handle activities
at both units.
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No items of noncompliance or deviations were noted.
4.
L_icensee Audi ts
The inspector examined audits performed by the licensee to determine
compliance with Technical Specification 6.5.2.
The plant QA staff
had' performed audits of Health Physics activities on the following
dates:
April 25 - May 1,1978
January 5 and 6, 1978
August 11-15, 1978
A licensee representative stated that the Safety Review Committee
(SRC) had performed an audit during July 1978.
Copies of the SRC
audit had not been distributed at the time of this inspection.
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It was noted that timely corrective action was completed for " hose
items identified in the licensee's audits.
No items of noncompliance or deviations were noted.
5.
Radiological Traning
The inspcctor examined the licensee's training program to determine
compliance with 10 CFR 19.12 and FSAR requirements. The following
areas were reviewed:
-Scope and content of training
-Initial training
-Refresher training
-Training of contractor personnel
-Documentation of training
Training records were examined for four (4) new AP&L employees,
thirteen (13) contract personnel, and twenty-one (21) permanent plant
employees.
No items of noncompliance or deviations were noted.
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6.
Radiological Protection Procedures
The inspector reviewed changes made to radiological protection proce-
dures to determine if the changes were consistent with Technical
Specification requirements.
It was noted that several changes have
been made since the previous inspection. All changes were properly
reviewed and approved.
No items of noncompliance or deviations were identified.
7.
Instruments and Equipment
The inspector examined monitoring instruments and equipment to verify
that they are operable, have the proper alarm setting and are calibrated
in accordance with procedures and Technical Specification requirements.
The following types of equipment and instruments were examined:
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-Portable survey instruments
-Fixed monitoring equipment (e.g. portal monitors, friskers, hand
and foot counters)
-constant air monitors
-Portable air monitors
-Pocket dosimeters
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-Personnel TLDs
-Area radiation monitors
No items of noncompliance or deviations were identified.
8.
Exposure Control
The inspector reviewed selected records for permanent plant employees,
transient workers, visitors, and terminated personnel to determine
compliance with 10 CFR 20 and Reg. Guide 8.14.
The licensee uses NTA film and track etch dosimeters for personnel
neutron monitoring.
However, the energies of the neutrons in the
plant have not been established. As a result, it has not been deter-
mined if the licensee's present monitoring program will satisfy
A licensee representative stated that an evaluation of neutron energies
will be performed. Based on the evaluation results, it maybe nec-
essary to update or supplement their present system.
This item is
considered unresolved pending the evaluation of the neutron energies.
See paragraph 15,
9.
Posting and Control
The inspactor made several visits to selected plant areas to observe
work activities and general plant conditions.
Specific attention was
given to the following items:
-Special Work Permit (SWP) and Radiation Work Permit (RWP) areas
-Housekeeping
-Visitor control
-Access control for restricted areas
-Identification and control of high radiation areas
-Identification and control of contaminated areas
-Radioactive materials storage areas
-Laundry facilities
-Health physics counting room
-First aid supplies
-Radioactive waste handling and storage areas
-Independent measurements made by the inspector
The above visits included a review of the licensce's program to
determine compliance with the following requirements:
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-10 CFR 19
-10 CFR 20
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-SWP/RWP requirements
-Technical Specifications
The following items were noted:
a.
During a tour of the radwaste drumming room on August 16, 1978,
the inspector identified whole body radiation levels up to
3 Rem /hr near two (2) spent resin shipping casks.
A " Caution -
High Radiation Area" sign was posted near the casks; however, the
entrance to the drumming room was not under direct surveillance,
equipped with a control device or locked.
Failure to control entrance to the high radiation area is an
apparent item of noncompliance against 10 CFR 20.203(c)(2).
b.
Container Labelling
While reviewing the licensee's g aled source program, the
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inspector noted that a 39 mci
Cs source, serial number 28S,
used to response test the AN0-2 process monitors was not properly
labelled. The source container did not bear the words " CAUTION,
RADI0 ACTIVE MATERIAL" or " DANGER, RADI0 ACTIVE MATERIAL," activity,
isotope, or date of assay.
Failure to properly label the source container is considered an
apparent item of noncompliance against 10 CFR 20.203(f)(2).
10.
Surveys
The inspector reviewed the license's survey program to determine
compliance with plant procedures, 10 CFR 20.201, and 10 CFR 20.401(b).
No items of noncompliance or deviations were identified.
11.
Notifications and Reports
The inspector review the licensee's records to determine compliar.ce
with the Technical Specifications and the following reouirements:
-10 CFR 19.13
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-10 CFR 20.402
-10 CFR 20.403
-10 CFR 20.405
-10 CFR 20.408
The inspector reviewed the records for (12) AP&L employees that had
terminated between August 1,1977, and April 30, 1978.
It was noted
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that the required termination reports of personnel exposure for
four (4) workers had not been furnished to the NRC or the individual.
Failure to furni-shed the required reports is considered an apparent
item of noncompliance against 10 CFR 20.408 and 10 CFR 19.13(d).
12.
Solid Radioactive Waste
The inspector examined the licensee's radioactive waste program to
determine compliance with the Technical Specifications, Reg. Guide 1.21,
and 10 CFR 71.
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On May 12, 1978, RIV received notification from the State of
South Carolina Department of Health that one of their licensees
(Chem-Nuclear Systems, Inc., Barwell, South Carolina) had received
a waste shipment containing liquid from ANO-1. The South Carolina
representative stated the Chem-Nuclear's license prohibits the burial
of liquid waste. The shipment consisted of nine (9) BIRM filter;
(TRI Nuclear Model DV-1490) identified by ANO-1 as shipment No. 23-78.
The nine (9) filters had been banded together and shipped in a large
Type B shipping cask. As the filters were being lifted from the
shipping cask at the burial site, the bands broke causing the filters
to drop. The inlet-outlet connections on one of the filters broke on
impact causing the filter contents to be spilled.
It was at this time
that the filter was observed as containing about 3-5 gallons of liquid
along with the spent resin.
Further investigation revealed that the
other eight (8) filters also contained liquid.
A BIRM filter, about the size of a household hot water heater, is a
disposable demineralizer vessel used for clean-up processing of
radioactively contaminated water.
Collectively, the nine (9) filters
contained about twelve (12) curies of transport group III material.
The shipment, classified as LSA material, left ANO-1 via sole use
vehicle on May 9, 1978.
Prior to having the facility, the licensee
certified that the shipment met DOT and 10 CFR 71 requirements.
In reviewing matters related to the shipment, the inspector noted
the following items:
a.
DOT Type 7A Containers
The filters had been certified as DOT Type 7A containers by
the vendor, TRI Nuclear Corporation, on March 27, 1978.
It
was noted that the certification specified bronze head castings
for the inlet-outlet connections. However, the filters in the
May 9,1978, shipment were fitted with plastic connections.
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Failure to use the proper shipping container is an apparent
item of noncompliance against 10 CFR 71.5.
b.
Absorbent Material
In order to satisfy shipping requirements, the nine (9) filters
were placed in a single Type B container (Certificate of Compliance
No. 6144, Revision 2).
Item 8 of the certificate No. 6144 states:
" Liquid contents must be additionally contained within an inner
containment vessel which is surrounded by sufficient absorbent
material to absorb at least twice the volume of the liquid
contents."
The May 9, 1978, shipment did not have the specified absorbent
material.
Failure to meet the required shipping conditions is an apparent
item of noncompliance against 10 CFR 71.5.
c.
Follow-up Corrective Action
The licensee's procedures specify that each spent filter is to
be back-flushed prior to shipment for the purpose of removing
any residual liquid.
Apparently, the liquid contained in the
filters was the result of improper back-flushing. The licensee's
records indicated that the problems associated with the shipment
were discussed with the burial facility, D0T, and the filter
vendor. However, the inspector was unable to find evidence that
any corrective action associated with back-flushing operations
was discussed to prevent future problems.
A licensee representative
stated that this problem will receive proper attention.
13. Health Physics Logs
The inspector reviewed radiological activities documented in the
licensee's Health Physics Logs for the period January 1, 1978,
through August 16, 1978.
It appears that the licensee does not have
a well established procedure for entries in a routine H.P. Log or
the documentation of Health Physics incidents.
A licensee represent-
ative stated that a program will be developed for documenting Health
Physics incidents and follow-up corrective action.
This same matter
was discussed in IE Inspection Report No. 50-313/78-01.
No items of noncompliance or deviations were identified.
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14. Analytical Measurements
Confirmatory measurements were performed on the following samples:
a.
Liquid waste
b.
Gaseous waste
c.
Stack charcoal cartrigde
d.
Stack particulate filter
Confirmatory measurement tests consist of comparing measurements
made by the licensee and NRC's reference laboratory, Idaho Health
Service Laboratory (IHSL).
IHSL's measurements are referenced to the
National Bureau of Standards by laboratory intercomparisons.
Confirmatory measurements are only made for those nuclides identified
by IHSL as being present in concentrations greater than 10% of the
respective MPCs for liquid and gas samples and above the Lower Limit
of Detection (LLD) for stack samples.
Stack charcoal cartridge and
particulate filter comparisons are based on established LLDs for
total activity per sample.
Attachment No.1 contains the criteria used to compare results.
Attachment No. 2 lists the LL0s for stack samples.
The following tables show the comparison results:
a.
Liquid (Monitor Tank T-16, Collected April 27,1978)
Nuclide
NRC Measurement
Lice see Measurement
Decision
2go
1.3 0.34E-06 uCi/ml
1.05 0.14E-06 uCi/ml
Agreement
Sb
1.2 0.2E-05 uCi/ml
1.08 0.05E-05 uCi/ml
Agreement
134Cs
1.6 0.11E-05 uCi/ml
1.42 0.03E-05 uCi/ml
Agreement
137Cs
2.7 0.13E-05 uCi/ml
2.41 0.02E-05 uCi/ml
Agreement
95Zr
6.4 1.3E-06 uCi/ml
4.76 0.36E-06 uCi/ml
Agreement
95Nb
5.7 0.7E-06 uCi/ml
7.56 0.2E-06 uCi/ml
Agreement
58Co
8.8 0.31E-05 uCi/ml
1.09 0.005E-04 uCi/ml
Agreement
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54Mn
1.1 0.9E-05 uCi/ml
1.22 0.002E-05 uCi/mi
Agreement
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59 Fe
4.2 1.6E-06 uCi/ml
6.13 0.3E-06 uCi/ml
Agreement
60Co
5.6 0.22E-05 uCi/ml
7.66 0.04EE-05 uCi/ml Agreement
124Sb
1.6 0.57E-06 uCi/ml
2.1$0.14E-06uCi/ml
Agreement
bgta
9.0 0.3E-05 uCi/ml
1.2-Q.05E-04 uCi/ml
Agreement
H
2.8 0.02E-03 uCi/ml
3.16-0.04E-03 uCi/ml
Agreement
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b.
Gaseous (Waste Gas Decay Tank, Collected April 27,1978)
Nuclide
NRC Measurement,
Licensee Measurement
Decision
1
I3 O 01E-02 uCi/cc
5.75 0.003E-02 uCi/cc
Agreement
Xe
y33
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2 7 O.1E-03 uCi/cc
1.45 0.01E-03 uCi/cc
Agreement
mXe
85
4,-0.02E-03 uCi/cc
4.51 0.03E-03 uCi/cc
Agreement
Kr
c.
Stack Charcoal Cartridge (Collected April 26,1978)
Nuclide
NRC Measurement
Licensee Measurement
Decision
I .08E-03 uCi/ sample Agreement
3.6 0.14E-03 uCi/ sample 1.8
Xe
2.2 0.44E-04 uCi/ sample 3.9)-Q.3E-04 uCi/ sample
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Agreement
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40K
3.3 0.34E-03 uCi/sainple 5.77-0.55E-03 uCi/ sample Agreement
d.
Stack Particulate Filter
Concentration identified by IHSL were less than LLDs.
No items of noncompliance or deviations were identified.
15.
Unresolved Item
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
noncompliance or deviations.
An unresolved item disclosed during
this inspection is discussed in paragraph 8.
16.
Ex'it Interview
At the ccnclusion of the inspection on August 18, 1978, the inspection
findings were discussed with the individuals denoted in paragraph 1.
The inspector reviewed the scope of the inspection and the inspection
findings.
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ATTACHMENT NO. 1
Criteria for Comparing Analytical Measurements
The following are the criteria used in comparing the results of capability
tests and verification measurements. The criteria are based on an empirical
relationship established through prior experience and this program's
analytical requirements.
In these criteria, the judgement limits vary in relation to the comparison
of the resolution.
Resolution = NRC Value
NRC Uncertainly
Ratio = Licensee Value
NRC Value
Comparisons are made by first determining the resolution and then reading
across the same line to the corresponding ratio.
The following table shows
the acceptance values.
RESOLUTION
RATIO
Possible
Possible
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Agreement
Agreement A
Agreement B
3
0.4 - 2.5
0.3 - 3.0
No comparison
4-7
0.5 - 2.0
0.4 - 2.5
0.3 - 3.0
8 - 15
0.6 - 1.66
0.5 - 2.0
0.4 - 2.5
16 - 50
0.75 - 1.33
0.6 - 1.66
0.5 - 2.0
51 - 200
0.80 - 1,25
0.75 - 1.33
0.6 - 1.66
7200
0.85 - 1.18
0.80 - 1.25
0.75 - 1.33
"A" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is
greater than 250 Kev.
Tritium analyses of liquid samples.
Iodine on adsorbers.
"B" criteria are applied to the followirig analyses:
Gamma Spectrometry where principal gamma energy used for identification is
less than 250 Kev.
89Sr and 90Sr Determinations.
Gross Beta where semples are counted on the same date using the same
reference nuclide.
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ATTACHMENT NO. 2
LLDs for Nuclides on Particulate and Charcoal Filters
Nuclide
LLD (uCi/ sample)
51Cr
54 n
1.5E-05
M
58Co
1.5E-05
59 e
F
57 o
C
60 o
C
65 Zn
89 r
5
90 r
S
131I
134Cs
137Cs
140Ba
140La
141 Ce
144Ce
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