ML20205N747
| ML20205N747 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/10/1986 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205N734 | List: |
| References | |
| 50-313-86-07, 50-313-86-7, 50-368-86-07, 50-368-86-7, NUDOCS 8605020280 | |
| Download: ML20205N747 (8) | |
See also: IR 05000313/1986007
Text
.
.
APPENDIX B
U.S. NUCLEAR REGULATORY COMISSION
REGION IV
NRC. Inspection Report:
50-313/86-07
Licenses: _DPR-51-
50-368/86-07
Licensee: Arkansas Power & Light Company
P. O. Box 551
Little Rock, Arkansas 72203
Facility Name:
Arkansas Nuclear One (ANO), Units 1 and 2
Inspection At:
ANO Site, Pope County, Russellville, Arkanst
Inspection Conducted:
March 17-21, 1986
Inspector:
n[ m M &M 4/
/hh
f.@,R. E. Baer, Padiat'
on Specialist, Facilities
Date
Radiological Protection Section
.
Approved:
d
,h4144tttLi
Yl0hkb
8.Murray, Chief, Faci /itiesRadiological
ITate '
Protection Section
Inspection Summary
Inspection Conducted March 17-21, 1986 (Report 50-313/86-07; 50-368/86-07)
Areas Inspected:
Routine, unannounced inspection of the licensee's radioactive
material transportation program, low-level radioactive waste storage facility,
and solid radioactive waste management.
Results:
Within the areas inspected, one violation was identified (failure to
verify stability of solid radioactive waste, see paragraph 7).
No deviations were
identifled,
f
8605020200 06
gg3
ADOCK
'
O
-
.
!
2
DETAILS
1.
Persons Contacted
,
-
i
l
- J. M. Levine, Director, Site Nuclear Operations
D. W. Akins, Radioactive Waste Supervisor
B. L. Bata, Quality Assurance (QA) Engineer
H. N. Bishop, Radioactive Waste Assistant Supervisor
!
- M. J. Bolanis, Health Physics (HP) Superintendent
l
- P. L. Campbell, Plant Licensing Engineer
'
J. W. Cheatham, Radioactive Waste Technician
R. M. Copp, QA Engineer
J. D. Deal, HP/Radwaste Trainer
"E. C. Ewing, General Manager, Plant Support
G. L. Fiser, Radiation Chemistry Supervisor
S. Forrest, Radioactive Waste Technician
- L. W. Humphrey, General Manager, Nuclear Quality
l
- D. B. Lomax, Plant Licensing Supervisor
l
W. C. McCorp, Quality Control (QC) Supervisor
A. M. McCullah, Radioactive Waste Technician
'
W. R. Pool, Assistant Radiation Chemistry Supervisor
- G. D. Provencher, QA Supervisor
'
- R. D. Rispoli, Fire Protection Specialist
S. P. Rcbinson, Radioactive Waste Assistant Supervisor
T. M. Rolniak, HP/Radwaste Lead Trainer
- E. L. Sanders, Maintenance Manager
- L. W. Schempp, QC Superintendent
- C, N. Shively, Plant Engineering Superintendent
D. D. Snellings, Nuclear Programs Manager
- G. A. Storey, Safety and Fire Prevention Coordinator
l
Others
S. S. Burrell, Radwaste Operator, NuPac Services Inc.
C. R. Fellhauer, Director, Customer Services, NuPac Services Inc.
- C. C. Harbuck, Resident Reactor Inspector, USNRC
- M. E. Murphy, Project Inspector, USNRC
,
l
l
The NRC inspector also interviewed several other licensee employees
l
including HP, chemistry, maintenance, and training personnel.
- Denotes those present at the exit interview on March 21, 1986.
2.
Inspector Observations
The following are observations the NRC inspector discussed with the
licensee during the exit interview on March 21, 1986.
These observations
are neither violations nor unresolved items.
L
.
.
3
These items were recommended for licensee consideration for program
improvement, but they have no specific regulatory requirement.
The licensee
indicated that these items would be reviewed:
a.
Low-level Radioactive Waste Storage Facility - The Updated Safety
Analysis Report (USAR) had not been revised to include the low-level
radioactive waste storage facility.
See paragraph 3 for additional
details.
b.
Radioactive Waste Volume Reduction Program - A radioactive waste
volume reduction program had not been established to reduce the volume
of waste to the licensee's projected volume.
See paragraph 3 for
additional details.
c.
Position Descriptions for Radwaste Personnel - The present position
descriptions f1r radwaste personnel do not accurately reflect the
duties and responsibilities of the position.
See paragraph 5 for
ar.ditional details.
3.
Low-Level Radioactive Waste Storage Facility
The NRC inspector reviewed the status of the onsite low-level radioactive
waste (LLRW) storage facility for compliance with facility license
coaditions and the recommendations of NRC Generic letter 81-38, NRC Office
of Inspection and Enforcement (I&E) Circular 80-18, NRC Regulatory
Guide (RG) 1.143 and NUREG 0800.
The NRC inspector determined that the licensee had completed construction
of an onsite LLRW facility as previously described in NRC Inspection
Reports 50-368/84-19 and 50-368/85-08.
The licensee's projected completion
date is September 1986 for the facility to be fully operational.
The NRC
inspector discussed with licensee representatives the need to revise the
USAR for both units to address the LLRW facility describing the purpose,
capability, and cperation.
The NRC inspector also reviewed the licensee
correspondence to the NRC dated February 25, 1985, which stated that the
total annual generation of LLRW for ANO is estimated to be approximately
24,000 cubic feet.
A review of previous LLRW shipments indicated volumes
of:
1985 - 25360 cubic feet, 1984 - 33110 cubic feet, 1983 - 25000 cubic
feet, ar.d 1982 - 32,500 cubic feet.
The NRC inspector noted that the
licensee would need to implement an aggressive radwaste volume reduction
program to achieve a goal of 24000 cubic feet per year.
The licensee
indicated an awareness of the need to reduce LLRW volumes.
No violations or deviations were identified.
4.
Waste Generator Requirements 10 CFR 20 and 10 CFR 61 - The NRC inspector
reviewed the licensee's program for disposal of LLRW to determine compliance
with the requirements to 10 CFR Part 20.311 and 10 CFR Parts 61.55 and 61.56.
The NRC inspector reviewed the licensee's LLRW program for generation of
waste manifests, waste classification, waste form and characterization,
labeling, tracking of waste shipments, and maintaining a current copy of the
7
. _ _
_ _ _ . _ _ _
__ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
.
.
4
disposal site license conditions.
The licensee was currently implementing
a LLRW program as described in NRC Inspection Report 50-368/84-19.
The NRC inspector determined that the licensee had solidified low-level
contaminated lubricating oils (approximately 12,000 gallons) in 608
55 gallon containers in accordance with station procedure 1603.017,
" Solidification of Contaminated Oil," Revision 0, March 14, 1985, which
incorporated the vendor's procedure OH-19, " Operating Procedure for Oil
Solidification System," Revisioa 1, February 22, 1985.
The NRC inspector
noted that the vendor's procedure did not require that samples be collected
and analyzed to demonstrate a free standing monolith is obtained although
Section 7.9 of procedure OM-19 requires that the final product be inspected
to verify that the waste is in a solid form.
The vendor's procedure
references PT-18, " Process Control Program for NVPAC Oil Solidification
System," Revision 0, February 22, 1985.
The NRC inspector requested
from the licensee and vendor representatives onsite a copy of PT-18, but
neither the licensee nor the vendor had a copy of the procedure.
10 CFR Part 20.311(d)(3) requires that any generating licensee who transfers
radioactive waste to a land disposal facility shall conduct a quality
control program to assure compliance with paragraphs 61.55 and 61.56 of
this chapter.
The NRC inspector stated that failure to have controlled copies of vendor
procedures and complete a successful sample solidification verification
to demonstrate compliance with 10CFR Part 61.56 is considered a violation
of 10 CFR 20.311(d)(3) (313/8607-01 and 368/8607-01).
5.
Organization and Management Controls
The NRC inspector reviewed the licensee's radicactive waste organization
and management controls to verify agreement with AN0's Technical
Specifications (TS) and USAR.
t
The NRC inspector determined that the licensee's radioactive vaste
management program is a separate section in the health physics group.
However, TS Figure 6.2-2 does not identify the radwaste group as a separate
section.
The Radioactive Waste Supervisor reports to the Health Physics
Superintendent and has two Radioactive Waste Assistant Supervisors that
report to him.
The NRC inspector reviewed the position description for the three radioactive
waste supervisory positions, positions 0461.0, 0462.0, and 0463.0 and noted
that tiese position descriptions, revised and approved in December 1953,
did not include all the responsibilities that are currently required of the
position including waste tracking methods, waste form and characteristic
determinations, and computer operations.
The licensee did not have position
descriptions for the technicians assigned to decontamination and radwaste
duties, rather a position task analysis for a health physicist / apprentice.
_ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ - - _ _ _ - _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
-
..
.
5
The licensee uses this group as an entry level into the health physics
I
technician area, which accounts for the high turnover rate, approximately
100 percent in two years, that exists in this section.
'
No violations or deviations were identified.
l
6.
Training and Qualifications
The NRC inspector reviewed the training and qualifications of personnel
.
l
'
assigned to the radioactive waste section to determine compliance with
licensee commitments to I&E Bulletin 79-19 and the requirements of
40 CFR 173.1(b).
The NRC inspector interviewed personnel responsible for radioactive material
transportation activities, reviewed the health physics training outlines and
select lesson plaas.
The NRC inspector noted that a vendor had presented a
l
course onsite which included the Department of Transportation (DOT)
requirements and burial site restrictions.
No violations or deviations were identified.
'
7.
Solid Waste Management
The NRC inspectur reviewed the licensee's solid radioactive waste management
program for compliance with TS Section 6.8.1 for both units and commitments
contained in USAR Section 11.1.3.3 for Unit 1 and Section 11.5 for Unit 2.
The NRC inspector reviewed procedure 1012.003, " Solid Radioactive Waste
Management Process Control Program for Arkansas Nuclear One Units 1 and 2,"
Revision 0, March 28, 1984, and Attachment A which contains the Process
Control Program (PCP).
The NRC inspector noted that the PCP,Section III,
addresses oily waste and states that this type of waste will be processed
in accordance with approved plant procedures.
The NRC inspector discussed
with licensee representatives that oily waste is considered wet waste and
the criteria contained in Section II of the PCP " Wet Waste" would also apply
to oily waste.
The NRC inspector had previously determined, see paragraph 4
of this report, that the approved plant procedures did not include all the
critical elements necessary to comply with Federal Regulations.
The licensee
indicated they would review this section of the PCP.
The NRC inspector also discussed the USAR solid radioactive waste sections
for both units with the licensee.
Neither Units 1 nor 2 USARs addressed
the capability for vendor solidification systems.
The licensee stated that these
sections of the USAR had been completely revised and would be submitted in
the next USAR update.
No violations or deviations were identified.
8.
Audits
The NRC inspector reviewed the licensee's last audit performed QAP-3-85
" Operating Plant Surveillance Audit Health Physics /Radwaste Management"
-
_
.
-_-
.
.
.
6
during the period December 20, 1985 through January 31, 1986.
The NRC
inspector also reviewed Quality Control (QC) surveillances,85-006,
85-031,85-068, 85-295,85-296, 85-297,85-305, 85-319,85-385, and
85-405.
The NRC inspector noted that several shipping activities which
would normally have been observed by QC on QC checklist 85-405 had been
completed by the radwaste group prior to QC being notified of the
shipment.
The eadwaste section routinely notifies QC of each shipment and
QC will selectively perform surveillances.
The NRC inspector determined
that both QA and QC personnel had attended a course on transportation
regulatory requirements,
No violations or deviations were identified.
9.
Transportation Activities
The NRC inspector reviewed the licensee's transportation program to
determine compliance with 10 CFR Parts 20 and 71, and DOT regulations
49 CFR Parts 170-189.
a.
Quality Assurance Program
The NRC inspector determined that the licensee had submitted a QA
program for approval to the NRC to comply with 10 CFR Part 71,
Subpart H.
The licensee had received NRC Form 311, Quality Assurance
Program Approval, approval number 0341, Revision 2, dated January 23,
1985.
b.
Procurement and Selection of Packaging
The NRC inspector reviewed the licensee's program for procurement and
selection of packaging against the requirements of.10 CFR Part 71.12
and 71.54 and 49 CFR Part 173.
The NRC inspector reviewed the licensee's procurement of 00T and NRC
certified packaging. The licensee had available the appropriate
documentation on design, use, maintenance, testing, and NRC/00T
certification,
c.
Preparation of Packages for Shipment
The NRC inspector reviewed the licensee's program for preparation of
packages for shipment to determine compliance with the requirements of
10 CFR Parts 20.311, 71.12, and 49 CFR Parts 172 and 173.
The licensee routinely used a checkoff list to assure that procedures
were followed and that packages were properly prepared in accordance
with DOT, state and burial site requirements.
,
J
. . . ,
7
,
d.
Delivery of Completed Packages to Carrier
The NRC inspector reviewed the licensee's program for delivery of
completed packages to a carrier for transport to determine compliance
with 10 CFR Parts 20.311, 71.55 and 49 CFR Parts 170 to 178.
The NRC inspector observed the licensee preparing, loading, labeling,
placarding, surveying, and completing shipping documentation for a
van loaded with Low Specific Activity (LSA) boxes containing
radioactively contaminated laundry.
e.
Receipt of Packages
The NRC inspector reviewed the licensee's program for receipt of
packages containing radioactive material to determine compliance with
The licensee's activities for receipt of radioactive material are
governed by procedure 1622.021, " Radioactive Equipment Receipt,
Storage, and Accountability," Revision 2, June 12, 1985.
The NRC
inspector reviewed this procedure for consistency with regulatory
requirements and to determine whether it covered all aspects of the
work being performed.
f.
Records, Reports, and Notifications
The NRC inspector reviewed selected records of 22 radioactive material
shipments of the 149 shipments made by the licensee during calendar
year 1985 and all 7 shipments made during period January 1 through
February 1,1986, for compliance with the requirements of 10 CFR Parts 20.311 and 71.62.
The licensee maintained records of all radio-
active material shipments as required.
The records were complete with
all shipping documentation, including the receipt and shipping radiation
survey data.
The NRC inspector reviewed the licensee's procedures for the radioactive
material handling and shipping program as contained in Attachment 1.
No violations or deviations were identified.
10.
Exit Interview
The NRC inspector met with the NRC resident inspector and licensee
representatives denoted in paragraph 1 at the conclusion of the inspection
on March 21, 1986.
The NRC inspector summarized the scope and findings of
this inspection, including the observations identified in paragraph 2.
The licensee stated that they would not solidify any contaminated oily
waste until a quality control program was inplace and implementing
i
procedures available to assure structural stability of the waste form.
t
-
-
. . - , -
-
-.-,
,-. .--,-= -,
--v _ --,
n=n-,
-
- . ,. ..
_
_
_
.
. .. .
ATTACHMENT 1
"
Procedures reviewed during NRC inspection 50-313/86-07 and 50-368/86-07.
I
1012.003, Solid Radioactive Waste Management Process Control Program for ANO
Units 1 and 2, Revision 0, March 28, 1984,
t
1603.003, Radioactive Material Shipments, Revision 12, July 3, 1985.
1603.004, Curie Content of Radioactive Waste Containers, Revision 4, February 1,
'
1985.
1603.006, Disposal of Spent Radioactive Resin, Revision 6, August 7, 1985.
1603.008, Guidelines for Classification and Marking of Radioactive Waste
Containers, Revision 3, October 31, 1985.
1
1603.011, Segregation of Radioactive Waste, Revision 3, April 22, 1985.
1603.012, Maintenance and Operation of the Nupactor Waste Compactor, Revision 4,
October 10, 1985.
1603.013, Operation of the Consolidated Balling Machine Waste Compactor,-
Revision 4, October 10, 1985.
1603.014, Packaging of Non-Compactable Radioactive Waste, Revision 5,
December 12, 1985.
1603.015, Radioactive Waste Management Program Surveillances, Revision 2,
l
January 30, 1985.
-1603.016, Encapsulation of Radioactive Waste, Revision 1, PC-1, May 24, 1985.
l
1603.017, Solidification of Contaminated Oil, Revision 0, March 14, 1985.
., .. -.
.
.
-
..
.
.