ML20205N747

Insp Repts 50-313/86-07 & 50-368/86-07 on 860317-21. Violation Noted:Failure to Verify Stability of Solid Radwaste Prior to Transfer to Land Disposal Facility

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: ML20205N731 ML20205N740 ML20205N747
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

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APPENDIX B

U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC. Inspection Report: 50-313/86-07 Licenses: _DPR-51-

50-368/86-07 NPF-6

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

on Specialist, Facilities Date

f.@,R.Radiological

E. Baer, Padiat'

Protection Section

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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,

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DETAILS

1. Persons Contacted

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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

' *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

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A. M. McCullah, Radioactive Waste Technician

W. R. Pool, Assistant Radiation Chemistry Supervisor

*G. D. Provencher, QA Supervisor

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• 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

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• M. E. Murphy, Project Inspector, USNRC

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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.

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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

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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.

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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.

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The licensee uses this group as an entry level into the health physics I

technician area, which accounts for the high turnover rate, approximately

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100 percent in two years, that exists in this section.

No violations or deviations were identified.

l 6. Training and Qualifications

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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.

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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"

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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.

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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

10 CFR Part 20.205.

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

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procedures available to assure structural stability of the waste form.

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ATTACHMENT 1

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Procedures reviewed during NRC inspection 50-313/86-07 and 50-368/86-07.

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1012.003, Solid Radioactive Waste Management Process Control Program for ANO

Units 1 and 2, Revision 0, March 28, 1984,

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1603.003, Radioactive Material Shipments, Revision 12, July 3, 1985.

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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.

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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.

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