ML20211A783
| ML20211A783 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1986 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Garde B GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| FOIA-85-490, FOIA-85-548, FOIA-86-A-155, FOIA-86-A-156 NUDOCS 8610170011 | |
| Download: ML20211A783 (6) | |
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^, UNITED STATES PblL-cit.
E o. NUCLEAR REGULATORY COMMISSION r, j- WASHINGTON, D.C. 20556
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$s'c*n'eEn'y"' October 6, 1986 Ms. Billie P. Garde, Director Environmental Whistleblower Clinic Government Accountability Project 1555 Connecticut Avenue, N.W..
Suite 202 IN RESPONSE REFER TO Washington, D.C. 20036 86-A-155(85-490)86-A-156(85-548)
Dear Ms. Garde:
This letter responds to your August 25, 1986 appeal of the denial of doc.uments in the Nuclear Regulatory Commission's July 14,-1986 response to FOIA~85-490 and 85-548. '
In response to your appeal, the documents were re-reviewed. Based on that review, portions of documents 1 and 21.-and documents 2, 24 and 28, Appendix C, are now being released, as listed in Appendix D. They are being placed in the NRC Public Document Room (PDR) located at 1717 H Street, N.W.,
Washington, D.C. 20555, in file folder FOIA 85-490 and 85-548 in your name.
With respect to the balance of the documents, I affirm the Agency's initial action. ' The withheld portions of document 1, Appendix B, consist of names -and other identifying information provided by a former. employee of the Farley Nuclear Power Plant. To disclose the names.and other identifying information concerning these individuals would constitute a clearly' unwarranted invasion of personal rivacy. This information is being withheld Exemptions ( ) and (7)(C) of the F0IA (5 U.S.C. 552(b)(6) pursuant toand7(C)and10 C.F.R. 9.5(a (6) and (7)(iii) of the Comission's regulations. See Dept. of Air Force v. Rose, 425 U.S. 352, 372-373 (1976); Stern v. FBI. 737 F.2d 84, 91 D.C. Cir.1984 ; Lesar v. United States Dept. of Justice, 636 F.2d 472, 486 D.C. Cir. 1980 .
In addition, the withheld portions of documents 1 and 21 and documents 2-20, 22-23, 25-27, and 29-37, Appendix C, must continue to be withheld under Exemption (7)(A) of the FOIA (5 U.S.C. 552(b)(7)(a) and 10 C.F.R. 9.5(a)(7)(1) of the Comission's regulations. The withheld infonnation consists of
" investigatory records compiled for law enforcement purposes, ..." the disclosure of which would " interfere with enforcement See NLRB
- v. Robbins Tire & Rubber Co., 437 U.S. 214, 222, 223.(proceedings." 1978). Release of this information could allow those being investigated to learn the scope, direction, and focus of investigatory efforts, and thus could possibly allow them to take action to shield potential wrongdoing or a violation of NRC requirements from investigators.
8ARDERA-A-tss pne . 1-1
Ms. Billie P. Garde, Director 2- October 2, 1986 This letter represents final agency action on your August 25, 1986, F0IA Appeal. Judicial review of. the denial of documents is available in Federal District Court in the district in which you reside or have your principal place of business, or in the District of Columbia.
I Sincerely, p'shPJ. -
5 Secretary pf the Commission Attachments: Appendices -)
4
Re: F01A-85-490 and g
. APPENDIX B Document Being Withheld in Part
- 1. 05/27/63 Memo from Vorse to Todd.
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Re: FOIA-85-490 and
, F0!A-85-548
. APPENDIX C Docurents Reing Withheld in Their Entirety
- 1. Undated Official Use Caly Cover Sheet
- 2. Undated Case Chronology
- 3. 03/17/83 Memorandum from Woodard to File 4 03/23/83 Inter Department Memorandum from Woodard to WCC .
- 5. 04/26/83 Menorandum from Carr to File
- 6. 06/05/85 Handwritten Memo from Wilkinson
- 7. 07/03/85 Menorandun from Wolfe
- 8. 07/08/85 Inter Department Memorandum from Crine to Walden
- 9. 06/24/85 Inter Department Memorandum from Walder.
- 10. 05/04/85 L'etter from A11eger to Uryc
- 11. 07/10/85 Letter to A11eger from Uryc
- 12. 06/03/85 A11egetion Report
- 13. 06/03/85 Allegation Report 14 05/07/85 Memorandum te Case File
- 15. 05/10/85 Memorandum to Case File
- 16. Undated Charge-Out Record .
- 17. 07/15/85 Certified Return Receipt
- 18. 07/16/85 Memorandum to File from Wolfe ,
- 19. Undated Official Use Only Cover Sheet
- 20. 05/14/84 Case Chronology
- 21. Undated Charge-Out Record
- 22. 04/05/84 Review Sheet
- 73. 05/11/84 Letter to Alleger from Lankford
- Re: FOIA-85-490 APPENDIX C (CONTINUED)
- 24. 03/27/84' Report No. 50-348/84-06 and 50-364/84-06
- 25. 03/23/84 Memorandum from Weddington to Todd -
- 26. 04/02/84 2-Way Memo from Uryc to Harrison
- 27. 03/14/84 Letter to A11eger from tankford
- 28. 01/12/84 Repert No. 50-348/83-32 and 50-364/83-30
- 29. 03/07/84 Memorandun. to Case File ~
- 30. 01/20/84 Memorandum to Case File ,
- 31. 01/09/84 Allegation Data Form
- 32. 01/16/84 Memo from Todd to Gibson
- 33. 01/10/84 Allegation Report
- 34. 01/13/84 Memorandum to Cas'e File
- 35. 01/10/84 Memorandum to Case File
- 36. 01/09/84 Allegation Report
- 37. 05/16/84 Certified Mail Receipt I
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APPENDIX D
- 1. 3/27/84 Letter to Alabama Power Co. (2 pps. ) , enclos-ing report of inspection of February 21-24, 1984; Inspection Report No. 50-348/84-06 and 50-364/84-06 Accession No. 8404170249
- 2. 1/12/84 Letter to Alabama Power Co. '(2 pps.) , enclos-ina report of~ inspection on December 12-16, 1983; Inspection Report No. 50-348/83-32 and 50/364/83-30 Accession No. 8402140159
- 3. Undated Official Use Only Cover Sheet
- 4. Undated Case Chronology Sheet
- 5. Undated Charge-Out Record
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- UNITED STATES
/ meeg#( UCLEAR CEOULATCOY COMMISSION gj t t. C W CE2 TOM ll
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! 101 M ARIETTA STREE7.N.W.
- ATLANTA, OEOA01 A 30303
'..... MAR 271964 Alabama Power Company ATTN: Mr. R. P~. Mcdonald Vice President-Nuclear Generation P. O. Box 2641 Birtningham, AL 35291 Gentlemen:
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SUBJECT:
REPORT NOS. 50-348/84-06AND50-364/84-06 On February 21 - 24, 1984, NRC inspected activities authorized by' NRC License Farley facility. At the conclusion of the Nos. NPF-2 and NPF-8 for inspection, the findings were your[ discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representstive records, interviews with personnel, and observation of activities in progress.
Within the scope of the inspection, no violations or deviations were identified.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in NRC's Public Document Room unless you notify this office by telephone within ten days of the date of this letter and submit written applica-tien to withhold infonnation contained therein within thirty days of the date of the letter. Such application must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this letter, please contact us.
Sine rely, D
ns id M. Y relli , Chief
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Project Branch 1 Division of Project and Resident Programs
Enclosure:
(See page 2)
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Alabama Power Company 2 ggg gy 19g4
Enclosure:
Inspection Report Nos. 50-348/84-06 ,
and 50-364/84-06 l 1
cc w/ enc 1:
W. O. Whitt, Executive Vice President F. L. Clayton, Jr., Senior Vice President H. O. Thrash, Manager, Nuclear Operations ,
and Administration O. D. Kingsley, Jr., Manager, Nuclear Engineering and Technical Services J. W. McGowan, Manager-Safety Audit and Engineering Review W. G. Ware, Supervisor-Safety Audit and Engineering Review W. G. Hairston, III, Plant Manager
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MAR 27 1984 Report Hos.: 50-348/84-06 and 50-364/84-06 Licensee: Alabama Power Company 600 North 18th Street Bimingham, AL 35291 Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley Inspection at Farley site near Dothan, Alabama Inspector: _
. 3/2_o/W R. E. Weddi Q Date Signed Approved by: k ,' z.I N m -l /2e K. P. Barr, SEctt5n Chief Oste Signed Operational Program Branch Division of Engineering and Operational Programs SUM 4ARY Inspection en February 21 - 24, 1984 Areas Inspected This reutine, unannounced inspection involved 36.5 inspector-hours on site in the areas of 10 CFR Part 61 implementation, debris removal from reactor cavity during Unit I refueling outage, plant tour and Unit 2 outage.
Results Of the four areas inspected, no violations or deviations were identified.
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REPORT DETAILS
- 1. Persons Contacted Licensee Employees
- R. V. Badham, SAER Engineer
- M. W. Mitchell Health Physics Group Supervisor
- C D. Nesbitt, Technical Superintendent
- J. M. Walden, Radwaste Supervisor
- W. G. Hairston, III, Plant Manager
- J. D. Woodard, Assistant Plant Manager
- D. N. Morey, Operations Superintendent B. P. Patton, Plant Health Physicist P. E. Farnsworth Health Physics Section Supervisor Other licensee employees contacted included eight technicians and three office personnel.
Other Organizations Tim Hope, IMPELL Corporation, Norcross, Georgia NRC Resident Inspectors
- W. H. Bradford, Senior Resident Inspector
- W. H. Ruland, Resident Inspector
- Attended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on February 24, 1984, with those persons indicated in paragraph 1 above.
- 3. Licensee Action on Previous Enforcement Matters Not inspected.
4 Unresolved Items Unresolved items were not identified during this inspection.
- 5. Debris Removal frcm Reactor Cavity During Unit 1 Refueling Outage Core upflow modifications had been performed during the Unit I refueling outage. The reactor cavity area contained high level debris as a result of this work. Also during fuel transfer, a fuel bundle had ruptured and the licensee was involved in recovering and accounting for the discharged fuel pellets. On March 5,1983, Special Radiation Work Permit (SRWP) 1-83-0200
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2 was prepared. The job description of the SRWP was " Decontamination of Unit I reactor cavity from wash down to final cleaning, including applica-tion and renibval of strippable paint." Section F of the SRWP contained the instruction to " ensure buckets and containers holding filings, pellets, etc., are kept below water level as cavity is drained." Baskets, or inserts, containing accumulated debris and recovered fuel pellets were below water level in storage racks or secured by hanging ropes. Since it was known that the contents of these inserts were sicaificEt radiation sources, the licensee SRWP -instruction was intended to maintain water- shielding -
between the inserts and the workers involved with the.r nity draining-and.
cleaning. The SRWP required continuous Health Physics coverage and the remarks section stated that Health Physics was "to change and adjust require-ments as changing dose rates and radiological conditions dictate".
The licensee planned to use the upender to transfer the inserts to the fuel storage pool. At some time during the course of work, approximately on the morning of March 6,1983, it was determined that the upender could not be used to transfer the inserts due to imoroper fit. The decision was made to remove the inserts from the water and place them in shielded containers
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adjacent to the reactor cavity on the 155' Elevation of Unit 1 Containment.
Prior to removal from the water, the inserts were loaded into 55 gallon drums that had holes in the bottom to promote drainage. Each drum could hold four inserts and was allowed to drain above the water surface prior to being transferred to the shielded container. The ifcensee had arranged for Health Physics management personnel to be present during this work evolution since they recognized the work would involve high levels'of radiation and they wanted to ensure it was properly controlled. The removal evolution subsequently proceeded without difficulty.
At approximately 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> on March 7,1983 a need was identified which required the removal of one of the drums from the shielded cask and for placement back into the water. The cask had a' shielded plug in place that l had to be removed. The 55 gallon drum inside the cask was equipped with a rope attached to a lifting device. The rope was placed in the drum when the shielded plug was installed. The licensee planned to remove the shielded plug from the cask with the polar crane. A worker was then to retrieve the rope by reaching into the drum and then crouch below the top of the cask and tie the rope to another rope on the polar crane. The worker chosen to retrieve the rope was an inexperienced radiation worker that had been transferred from his previous nonradiological position to augment the work force for the outage. A briefing was conducted in containment for the I worker and the Health Physics Technican assigned to provide coverage. The worker retrieved the rope as planned from the cask but had difficulty in tying the rope to the one suspended from the polar crane. The Health Physics Supervisor went to his assistance and succeeded in tying the ropes.
The Health Physics technician during this time was monitoring radiation levels with a Teletector and providing instructions for the personnel to take advantage of the shielding afforded by the cask. When the polar crane operator started to. take the slack out of the line, the signalman (rigger) stopped the lift because it appeared questionable. The shielded plug was' then placed back on the cask. At this time, it was discovered that the l- - -- - - - _ - . - - - - _ _ - _ - _ - _ _ _ -_ - _ _ _ - -
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workers' high range pocket dosimeter was offscale and he was directed .to exit containment and report to the dosimetry section to have his TLD read.
The licensee documented this event in Radiation Incident Report 83-0234, dated March 7,1983. The report states that the workers' whole body -TLD badge (which was worn on the upper chest) read 280 millirem. He also had worn an extremity TLD finger ring on each hand which read 21 millirem, right hand, and 39.3 millirem, left hand. The licensee's evaluation concluded that the 280 millirem was his actual exposure and that no exposure limits had been exceeded. The 280 millirem also included exposure he had received on a Unit I containment entry the previous shift for which his high range pocket dostmeter had read 300 millirem. The licensee's surveys indicate that the radiation level at the top of the cask was 50 Rem / hour and 150 millirem / hour along the shielded sides of the cask.
The inspector determined that the licensee's evaluation of the worker's exposure was accurate. The accounts of the involved parties including the worker, concerning the length of time the worker was over the cask and the radiation survey data contributed to this conclusion. The task was also
- successfully reattempted approximately two hours later with a different 4
worker and his exposure was consistent with the first workers'. The inspec-
! tor asked to be shown a cask similar to the one associated with the event in i . order to determine if there had been a problem associated with the worker wearing his TLD badge on his chest as opposed to on the head. The inspector had received several. eyewitness accounts as to how the rope retrieval occurred and he reenacted the task. The inspector determined that the chest was closer to the radiation source than the head, unless the head was placed-below the top plane inside the cask, which by all accounts the worker did not do.
The inspector then asked to see the SRWP for the handling of the inserts out of the water. The licensee stated that they thought that the work had been accomplished under a provision of their local procedures which permitted full time coverage by a Health Physics technician to be used in lieu of a l SRWP. The inspector asked to see the procedure that was in effect at the time of the event and was shown Farley Nuclear Plant Radiation Control and Protection Procedure .(FNP-0-RCP)-2, Radiation Work Permit, dated August 3, 1982. The inspector noted that paragraph 5.3 of the procedure did allcw the option of using Health Physics coverage in lieu of a SRWP, but stated that this option was for " unusual circumstances" and that an RWP should be completed after the fact for documentation purposes. The inspector inquired into the definition of " unusual . circumstances" and was told that an example -
would be that plant operations had to enter an area to inspect for leakage and there was not time to prepare a SPWP. This definition is consistent with a change made to the subject procedure the following month which provided the clarification " unusual circumstances (i.e., Emergency Condi-tions)." The inspector stated that he failed to understand the urgency of the task that would permit use of this option since the drums or inserts were in a stable conditon, either underwater or inside a shielded cask. He <
then asked the licensee for the documentation SRWP required by RCP-2. i l
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. l The next day the licensee infomed the inspector that they had researched the event and determined that the work had been accomplished under SRWP 1-83-0200 and that they had not utilized the option of using full time Health Physics Technician coverage in lieu of a SRWP. The inspector observed that .the special remarks section of this SRWP would seem to speci-
. fically prohibit removing any of the inserts from the water. The licensee stated that the instruction was intended to be applicable only when the cavity water level was actually being lowered. The inspector then asked to be provided all of the licensee records related to this event. Numerous survey records were reviewed to determine if an alpha radiation problem was present during the time frame of this event. The licensee had performed evaluations for alpha radiation and no problem was discovered. The inspec-tor then reviewed the time sheets for SRWP 1-83-0260 and observed that two of the three personnel named by the licensee in the Radiation Incident Report as the ones who had successfully returned the insert to the water after the initial event were not logged in on the SRWP 1-83-0200 time sheet.
The licensee stated that these were Health Physics personnel and they had entered the containment under the general Pealth Physics Surveillance
, (SWRP). The inspector then reviewed licensee survey record 1-83-2490 which J
documented the surveys perfomed on two drums of inserts as they were removed from the water on March 6,1983 at 0730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br />. The survey records
- indicated that the survey was being . performed for SRWP 1-83-0101. The inspector reviewed this SRWP and noted that it was written for the co's upflow modification, did not discuss removal of inserts from the water and had been formally closed out by Health. Physics on February 26, 1983. The licensee stated that perhaps the technician had mistakenly entered the incorrect SRWP number on his ' survey record.
Due to the age of the event., circunstances surrounding it could not be clearly confirmed; thus no violation of deviation will be issued. The inspector informed the licensee that an Inspector Follow-Up Item would be established to evaluate the licensee RWP system as it currently exists to detem'ine if RWP's are being written in sufficient detail to clearly estab-lish the controls for major radiological tasks in the work evolution (IFI 348/364/84-06-01).
- 6. 10 CFR Part 61 Implementation During the week of the inspectiori, the licensee performed their first low level radioactive waste shipment under 10 CFR Part 61 since the new regula-tion was effective on December 27, 1983. Although the licensee could have continued making shipments under an interim procedure, they elected to place a hold on all waste shipping until they had received analytical results of their waste stream samples from a vendor laboratory and could establish permanent procedures. The shipment was a HN-100 Shipping Cask containing fourteen 55 gallon drums of floor drain and radioactive waste tank sludge solidified in cement. The total activity of the shipment was 6,392 milli-curies and was classified as Class-A, Stable. The inspector reviewed the shipping manifest and associated shipping papers and determined that they were satisfactorily prepared. The licensee is in the process of performing qualification testing for their solidification processes. The solidifica-
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5 tion is currently being performed under the licensee's process control
, program, which includes a demonstration product from each batch to verify solidificati6n. The licensee has also established a tracking system for low level radioactive waste shipments to comply with 10 CFR 20.311.
The inspector reviewed three approved licensee- procedures which implement 10 CFR Part 61. FNP-0-RCP-809. Isotopic Characterization of Radioactiva Materials .for Offsite Shipments and/or Burial FNP-0-RCP-819, Waste Classi-fication for Near-Surface Disposal .and FNP-0-RCP-820, Scaling Factor Utili-zation' for Waste Classification. The licensee has obtained the services of an outside contractor to develop a computerized compliance program for Part 61 which is not yet available. The contractor has provided tables of scaling factors which permit the determination of concentrations of isotopes which cannot be measured on site based on concentrations of isotopes that can be measured on site. FNP-0-RCP-819 contains a form that provides a manual method of calculating waste classification until the ' computer soft-ware is available. FNP-0-RCP-820 contains tables of scaling factors based cn offsite radiochemistry analysis of the licensee's. waste streams. The inspector took the analytical data from the licensee's first Part 61 ship-ment and applied the scalirg factor procedure to see how well the calculated concentrations would compare with actual measurements. The irspector noted
, that there was disagreement between the two results for several isotopes by greater than a factor of ten. The inspector stated that there should be better agreement between the two results. The licensee showed the inspector a comparison study they had just performed of calculated concentrations and l actual measurements and in every case at least one isotope was in disagree-ment by greater than a factor of ten. The licensee' stated that their contrac-tor had developed the scaling factors based on actual Farley sample data and did not have an explanation for the discrepancy. The inspector noted that 10 CFR 61.55(a)(8) permits use of indirect methods, such as scaling factors, to determine concentrations of isotopes that cannot be easily measured pro-vided there is reasonable assurance that the indirect methods can be corre-I lated with actual measurements. NRC Low-level Waste Licensing Branch has published implementation guidance on 10 CFR 61, which the licensee is in possession, which established the factor of ten criteria for correlation.
The licensee contacted their contractor, to discuss formulation of scaling factors. The inspector was present for the conference. call. The contractor stated that in some cases Farley specific data is combined with data from other plants in order to refine the scaling factors if they feel they cannot confidently establish scaling factors based on the quantity of analytical data provided by the licensee. It was also stated that the contractor has not yet established the manner in which scaling factors will be adjusted as new analytical data becomes available. The concern is that the most recent sample, if it is representative 1y obtained, probably most accurately charac-terizes the waste product. If the new data is combined with' previous sample data the results obtained may not be as accurate if the old data is no longer representative of the waste stream due to changing plant conditions. The licensee stated that they would shortly be performing dry active waste (DAW) shipments using scaling factors. The inspector noted that the scaling factors and actual measurements for DAW differed by greater than a factor of ten for thirteen' (13) of the ninteen (19) isotopes in the table. The licensee
6 indicated that they would evaluate the matter further prior to making a radioactive waste shipment, but expressed a reluctance to deviate from-their contractor provided implementation program. The inspector observed that strong justification would seem to be recuired in order to use a cal-culated waste classification value that disagreed with an actual measure- i ment by greater than a factor of ten. The inspector informed the licensee !
-t that their evaluation of scaling factor and sample analysis data disagree-ment would be carried as an Inspector Follow-up Item for the next routine inspection (IFI 348/364/84-06-02).
- 7. Plant Tour The inspector toured the Service Building, Auxiliary Building and Units 1 and 2 Reactor Buildings to observe for compliance with posting and labeling requirement, compliance with Radiation Work Permits and local procedural requireme.:t, and housekeeping. The Health Physics Field Office, dosimetry section, chemistry counting rooms, whole body counter, Unit 2 Containment Access Point, decontamination room, hot machine shop, RCS sample rooms.and radioactive material storage areas were specifically visited. Work activi-ties observed were being conducted per applicable requirements. Licensee Health. Physics technicians were maintaining close follow-up of the work being performed. Licensee posting and labeling met regulatory requirements.
The licensee was making a considerable effort to maintain housekeeping in a
- high state during the outage.
No violations or deviations were noted.
- 8. Unit 2 Outage The inspector reviewed the licensee's radiological controls for the present outage. It was evident that extensive preplanning and ALARA reviews had been perfomed. The Plant Health Physicist was involved in obtaining the
! use of a vendor robotics system for steam generator tube rounding subsequent to eddy current measurements to reduce man-rem exposure. The licensee sus-l pected that they would have an iodine release in containment when the reactor l
vessel head was removed and they had provided a purge for the void under the I
head to the containment filtered ventilation system for two days prior to lifting the head. They had also sought NRR approval to take protection factor credit for iodine filter respirator cannisters for use during this work. Even though they had not obtained approval by the start of the outage, they elected to provide personnel the protection of the iodine cannister and not take pro-tection factor credit. When the reactor vessel head was lifted, the personnel in the cavity were provided the'added protection of dual flow air fed respira-i tors. Portable air samples taken when the head was lifted showed 0.5 Maxiu.um Permissible Concentration (MPC) for combined iodine and particulates, less than anticipated.
l The week prior to the inspection, the licensee encountered unanticipated l high beta radiation levels when the steam generators were opened and j stopped work until they had properly evaluated the exposure control consi-i derations. The highest radiation levels were in B loop steam generator hot
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leg side. The levels were 46 R/ hour gamma on contact, 22.R/ hour gamma general area and 308 R/ hour beta on contact. The. licensee provided shield-ing in the steam generators and then placed. test TLD arrays wrapped in various: combinations of protective clothing to better evaluate the exposure picture. They also obtained smear samples from the steam generators and evaluated means of attentuating beta radiation with eye protection ' devices.
The licensee determined that a clear air supplied hood and two lens thick-nesses of safety goggles was sufficient to shield the beta radiation to the eyes below the level where this exposure would be a limiting exposure control consideration. After this evaluation, steam generator work was resumed. The licensee was strictly enforcing an administrative exposure ,
control limit of 2150 millirem whole body and had refused numerous requests !
for exposure increases. No violations or deviations were noted.
- 9. Inspector Follow-Up Item (Closed) (IFI) (348/364/83-30-01) - Determination of Source Term For A Fire In The Rad Waste Building The licensee acknowledged that they would not be able to calculate a true source term if there was a fire in the new Rad Waste Building. It was also noted in the previous inspection that the only inventory list was maintained in the Rad Waste Building and might be difficult to retrieve in case of a fire. The licensee has changed plant procedure FNP-0-RCP-0815, paragraph 4.1 to require that a duplicate log sheet, CHP Form 504, be maintained in the facility document control section in the Service Building. The log sheet will be updated on a monthly basis. In case of a fire, the log sheet will be used to estimate the total activity released. The inspector informed the licensee that their actions appeared adequate and that this Inspector Follow Item was closed.
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y' ]og NUCLEAR REGULATORY COMMISSION
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o REGION 11
. g I 101 MARIETTA ST, N.W, St#TE 3100 u a ATLANTA, GEORGtA 30303 9h .,***** / ,
Janua ry 12, 1984 .
Alabam'a Power Company ATTN: Mr. R. P. Mcdonald
. . Vice President-Nuclear Generation
. P. O'. Box 2641 Birmingham, AL 35291 --
Gentlemen: .
SUBJECTi REPORT N05, 50-348/83-32 and 50-364/83-30 On December 12 - 16, 1983, NRC inspected activities authorized by NRC License Nos. NPF-2 and NPF-8 for your Farley faci _lity. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report. kithin these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.
Within the scope of the' inspection, no violations or deviations were identified.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in NRC's Public Document Room unless you notify this office by telephone within ten days of the date of this letter and submit written applica-tion to withhold information contained therein within thirty days of the date of the letter. Such application must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this letter, please contact us.
Sincerely.
David M. Verrel 1. Ch[ief Project Branch 1 Division of Project and Resident Programs
Enclosure:
(Seepage 2) f
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Alabama Power Company 2 Janua ry 12, 1984 .
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Enclosure:
Insepction Report Nos. 50-348/83-32 and 50-364/83-30 l
cc w/ enc 1: . .
W. O. Whitt, fxecutive Vice President ---
F. L. Clayton, Jr. ,' Senior Vice President H. O. Thrash, Manager, Nuclear Operations and Administration O. D. Kingsley, Jr., Manager, Nuclear Engineering and Technical Services J. W. McGowan, Manager-Safety Audit and Engineering Review W. G. Ware, Supervisor-Safety Audit and Engineering Review W. G. Hairston, III, Plant Manager e
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sysg UNITED ST ATES
- */ JCLEAR REGULATORY COMMISSION 2 cEilON 11 h* 101 M ARIETTA STREET,N.W.
- ATLANTA. GEORGI A 30303 -
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Report Nos.i 50-348/83-32 and 50-364/83-30 Licinsee:~ Alabama Power Company 600 North 18th Street -
Birmingham, AL 35291 ___
Docket,Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley Inspection at Farley site near Dothan, Alabama Inspector: N / (T B. T. Debs A Date Signed Approved by: f h s/ie/EV-K. P. 'Barr,Wion Chief Datt Signed Operational Programs Branch Division of Engineering and Operational Programs k
SUMMARY
Inspection on December 12 - 16, 1983 Areas Inspected .
This routine, unannounced inspection involved 32 inspector-hours on site in the areas of radioactive material shipping, low level radioactive waste storage building, effluent monitoring, health physics operations, resin loading of transuranic material,10 CFR 61 implementation, and total plant rem exposure.
Results Of the seven areas inspected, no violations or deviations were identified in the seven areas. *
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REPORT DETAIL'S
- 1. gPersgns Contacted Licensee Employees
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- J. D. Woodard, Assistant Plant Manager
- C. D. Nesbitt, Technical Superintendent
- B. P. Patton.. Plant Health Physicist
- J. M. Walden, Radwaste Supervisor
- P. E. Farnsworth, Health Physics Sector Supervisor M. W. Mitchell, Health Physics Supervisor
- W. G. Ware, SAER Supervisor Other' licensee employees contacted included six technicians, one operator, three security force members and two office personnel. ,
NRC Resident Inspectors
- W. Bradford, Senior Resident Inspector ,,
- W. Ruland, Resident Inspector
- Attended exit interview ,
- 2. Exit Interview The ir. pection scope and findings were summarized on December 16, 1983, with those ,ersons indicated in paragraph 1 above.
- 3. Licens e Action on Previous Enforcement Matters -
Not inipected.
- 4. Unreso'ved Items Unreso ved items were not identified during this inspection.
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S. Radioactive Material Shipping ,
The inspector observed licensee preparation of radioactive waste LSA ship-ment F4Sf83-33, volume allocation N6. 1283-196-A for shipment on
. Decembe r 13, 1983 to Chem-Nuclear Systems, Inc. , Barnwell, South Carolina.
The sh pment contained 26 packages consisting of steel drums and wooden boxes with a total curie content of 1382.8 millicuries.
Prepari tion and loading of the shipment were performed in accordance w'ith Farley Nuclear Plant (FNP)-0-RCP-810 " Shipment of Radioactive Waste to f
Barnwe 1 Burial Site."
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8 The inspector reviewed the aforementioned procedure ' alo'ng with F.NP-0-RCP-811. " Shipment of Radioactive Material." These procedures had been revised on November 13, 1983. In Inspection Report Nos. 50-348/83-16 and 50-364/83-14; the inspector had opened an. Inspector Followup Item
-~{348/83 16 05 364/83-14-05) regarding the licensee's lack of a ~ shipping checklist = in their radioactive material shipping procedure. The inspector observed that the current revision to that procedure has incorporated a shipment' check list along with the recent revisions to 49 CFR and 10 CFR 71.
The inspector further observed that both of 'the aforementioned procedures had been revised in such a manner as to provide detailed instructions to -
personnel performing radioactive shipping activities. The inspector also selectively reviewed the licensee's' shipping documents associated w'+h the 33 radioactive waste shipment made to date for calendar year 1983. No discrepancies were noted.
The licensee has shipped approximately 17,180 cubic feet of radioactive waste for calender year 1983 and is maintaining a near zero radioactive waste inventory 01 site.
The inspector informed licensee management that no violations or deviations were noted in this area. Furthermore, IFI 348/83-15-05 and 364/83-14-05 are closed by this inspection. -
A. 6. Solid Low Level Radioactive Waste Storage Building.
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An inspection was conducted of the licensee's recently completed low level radioactive waste storage building. The inspector performed radiation
- surveys around the fenced perimeter of the building and inside the building.
The inspector also observed the posting and labeling of the perimeter fence, the building, radioactive material stored in the build ng, and the calibra-tion periodicity of the building's alarming ra'diatic i monitors. No anomalies with federal regulations or plant procedures were observed.
The inspector reviewed FNP-0-RCP-803 " Operation of the Radwaste Building" issued October 23, 1983. The inspector noted that ir the event of a building fire and since no ventilation airborne radicactivity monitors service the building; a source term would be calculated by procedure from the current inventory of radioactive material stored ir the building. The inspector noted that tre only copy of the building material log is main-tained in the building and maybe difficult to retrieve in the event of a fire. The inspector later telephonically inquired as o how such a source term could be calculated in the event of a. fire. The licensee acknowledged the inspector's concern stating that information regarcing this item would be provided to the inspector at a later date. The 11spector informed licensee management that this matter would be tracket as an Inspector FollowupItem(50-348/82-32-01,50-364/83-30-01).
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- 7. Effluent Mofiitoring The inspector reviewed the licensee's current effluent control procedure -
FNP-0-RCP-705, " Liquid Waste Release Program," revised July 21, 1983 and FNP-D-RCP-706, " Gaseous Waste Release Program" revised August 25, 1983.. The inspector also reviewed selected liquid waste' release permits. ,
The inspector found the procedures to be adequate. No violations or devia-tions were noted in this area.
The inspector obtained four silt samples from stonn drain discharges located on the licensee's owner controlled property. The licensee currently does not have a program for periodically sampling these locations for radio-activity. A qualitative analysis of these samples perfonned by the licensee did not indicate any presence of licensed radioactive material. The inspector had no further questions.
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- 8. Health Fhysics Operations The inspector selectively reviewe'd the calibration data and instrument reading logs associated with radiation monitors R-2 g ,7,- 11,12,14,17A, 24A and 24B from July 1983 to. December 1983. No discrepanices were noted.
I The inspector reviewed the licensee's survey log being maintained for the.
\ unrestricted release of material from the licensee's protected area. The l logs indicated that all the material releasdd had no detectable contamina-tion greater than 200 disintegrations per minute per smear of 100 square centimeters or per scan.
The inspector observed health physics technicians performing a contamination
! survey within the auxiliary building. The inspector noted that licensee
! technicians would take large area smears (greater than 100 centimeters)'with an absorbent wipe). Licensee management informed the inspector that this practice is only used for informational data and that the. contamination '
survey of record are taken with standard smear discs over an area of 100 centimeters s'quared. It was also observed that the smear discs used by the licensee appeared to be constructed of a canvas material.
The inspector questioned whether these smears are degradable -inside tr.e primary system since they are often used inside the system. The licensee was not sure of the degradability of the smears at system operating temperatures and flow rates or the consequences of " lost" smears in tre primary system. The inspector informed licensee management that this ma-ter would be considered an Inspector Followup Item (50-348/83-32-02, .50-36*/
j 83-30-02).
i The inspector reviewed recent Health Physics technician continuin- trairing.
The training, which was conducted during this inspection, include d instru-r"' mentation, operational procedures, and plant systems descripticns and
( functions. No violations or discrepancies were observed.
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- 8. Resin Loading of Transuranic Material 2' In Mar '1983, the inspector opened an Unresolved Item URI (348/83-16-01,
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.364-14-01); the details of which are contained in Inspection Report
. ' 50-348/83-16 and 50-364/83-14. The unresolved item dealt with the in possibility of transuranic licensee radioactive process materials systems,existing"above
.especiaHy the disposal filtrationlimits, and ion i exchange medias, which had been or were going to be shipped to the Chem-Nuclear systems, Inc. at Barnwell, South Carolina for disposal.
Subsequent to the aforementioned inspection, the licensee obtained samples from their recycle holdup tank, waste monitor tank demineralizer, dry active waste, floor drains, mechanical filters, decontamination mop heads, IA and IB mixed bed resin. These samples were sent by the licensee to Science Applications, Inc. for analysis. Additionally these samples were split with the NRC for confirmatory measurement. The sample data from the'NRC was consistent with licensee's contractor.
Only one of the samples indicated alpha emitting transuranics greater than
] 10 nanocuries per gram that sample showed 12.7 nanocuries per gram of alpha emitting transuranics and was from the IB mixed bed resin which had not been shipped for disposal. This same resin indicated 16E nanocuries per gram of Beta emitting transuranics. The sludge sample from the floor drain tank contained 23.6 nanocuries per gram of Beta emitting transuranies. This material also had not been disposed of off-site. The Chem-Nuclear System's license limit of 10 nanocuries per gram issued by the State of South Carolina did not distinguish between the more hazardous alpha emitting transuranic isotopes and less hazardous beta emitting isotopes. A variance regarding . the concentration of 3 eta emitting transuranics was issued by j South Carolina to the Barnwell site for the subsequent disposal of the Farley resin. - As of December 27, 1983, this difference has been reco5nized i
ir.10 CFR 61 and amendment 36 tc Chem Nuclear's license 097. The inspector had previously informed licenset management that this unresolved item is considered closed with no violat ons identified.
- 9. 13 CFR 61 Implementation The licensee is adopting the WASTETRAK data file by the IMPELL Corporation.
2 Tne licensee is a member of a Lsers group called Utility Nuclear Waste Management Group which is working on the IMPELL methodology of waste classification.
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- Tne inspector reviewed a proposed plant procedure .for sampling and waste c'assification which, in part, 2ddresse,s mechanical filters, dry active i nste, primary resins, and LRS re sins and carbon. Although the procedure is in draft form, the licensee anti ipated in-housie acceptance of the procedure by the December 27, 1983, impler antation date. Some contract vaste stream sample analysis are outstanding wt the licensee expects the sample data no
( (t later than January 3,1984. Th licensee indicated to the inspector that radioactive waste shipments will be curtailed on December 27,1983, if the sample data has not been received, but sill resume whan the. data is received.
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The licensee should on or near December 27, 1983, have 'a ' process control program incorporating 10 CFR 61 and 10 CFR 20.311 along with waste classi-fictai6n procedures which ensure class B and class C waste are in stable
. form since these procedures exist in near final draft forin at the time of
'this~inspegtion. No violations or deviations were noted.
- 10. Total Plant Rem Exposure 1983 The inspector reviewed the licensee's exposure data for calendar year 1983.
The licensee had projected a 1983 total exposure of approximately 850 rem.
As of the end of November 1983, cununulative exposure was 832.51 rem for both units. The licensee does not anticipate exceeding their projection. This value -is considerably less than the 1304 rem (2 unit) average of PWRs
. obtained from NRC data in 1981.
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