ML20197C530

IE Inspec Rept 50-313/78-14 on 780814-18 During Which 4 Items of Noncompliance Were Noted:Failure to Control High Radiat Areas,Improper Radioactive Shipment & Failure to Label Matls

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: IR 05000313/1978014 ML20197C508 ML20197C515 ML20197C530 ML20197C548
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. DPR-51

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) l

Location: Russellville, Arkansas

Inspection Conducted: August 14-18, 1978 i

Inspector: M L+1

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81aihe' Murray,' Radiation 1 Specialist /3/17

/ Datd

Approved by: if , qJ//A1

"G1efi D. Brown,' Chi'ef, Fue'l Facility and

h/ DathO!N

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. ,

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

Reg. Guide 8.14.

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:  !, -

-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 gy aled source program, the

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

l -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

134

Sb 1.2 0.2E-05 uCi/ml 1.08 0.05E-05 uCi/ml Agreement

137

Cs 1.6 0.11E-05 uCi/ml 1.42 0.03E-05 uCi/ml Agreement

95

Cs 2.7 0.13E-05 uCi/ml 2.41 0.02E-05 uCi/ml Agreement

95

Zr 6.4 1.3E-06 uCi/ml 4.76 0.36E-06 uCi/ml Agreement

58

Nb 5.7 0.7E-06 uCi/ml 7.56 0.2E-06 uCi/ml Agreement

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Co 8.8 0.31E-05 uCi/ml 1.09 0.005E-04 uCi/ml Agreement

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Mn 1.1 0.9E-05 uCi/ml 1.22 0.002E-05 uCi/mi Agreement

60

Fe 4.2 1.6E-06 uCi/ml 6.13 0.3E-06 uCi/ml Agreement

124

Co 5.6 0.22E-05 uCi/ml 7.66 0.04EE-05 uCi/ml Agreement

Sb 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

3I O 01E-02 uCi/cc

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y33 Xe 5.75 0.003E-02 uCi/cc Agreement

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mXe 2 7IO.1E-03 uCi/cc 1.45 0.01E-03 uCi/cc Agreement

Kr 4,-0.02E-03 uCi/cc 4.51 0.03E-03 uCi/cc Agreement

c. Stack Charcoal Cartridge (Collected April 26,1978)

Nuclide NRC Measurement Licensee Measurement Decision

Xe 3.6 0.14E-03 uCi/ sample 1.8 I O.08E-03 uCi/ sample Agreement

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1 2.2 0.44E-04 uCi/ sample 3.9)-Q.3E-04 uCi/Agreement sample

K 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

Agreement Agreement A Agreement B

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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 1E-04

54Mn 1.5E-05

58Co 1.5E-05

59Fe 3E-05

57Co 2E-05

60Co 3E-05

65 Zn

3E-05

895 r 1E-05

90S r 2E-07

131I 2E-05

134Cs 2E-05

137Cs 2E-05

140Ba 2E-05

140 La

141 Ce

4E-05

2E-05

144Ce 1E-04

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