ML20214S554

Insp Repts 50-313/87-06 & 50-368/87-06 on 870322-27. Violations Noted:Failure to Follow Tech Specs Re Monitoring of Radioactive Effluents & to Perform Airborne Radioactive Measurements.Deviation Noted:Failure to Comply W/Fsar

ML20214S554
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/1987
From:	Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214S386	List: ML20214S383 ML20214S502 ML20214S513 ML20214S554
References
50-313-87-06, 50-313-87-6, 50-368-87-06, 50-368-87-6, NUDOCS 8706090320
Download: ML20214S554 (10)

See also: IR 05000313/1987006

Text

, .

APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/87-05 Licenses: DPR-51

50-368/87-06 NPF-6

Dockets: 50-313

50-368

Licensee: Arkansas Power and Light Company ( AP&L)

P.O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One (ANO)

Inspection At: AN0 Site, Russellville, Pope County, Arkansas

Inspection Conducted: March 22-27, 1987

n

Inspector: "

/ 6

H. Chaney, RidiAtton Specialist, facilities Dats

Radiological Protection Section

Approved: /]AOhl)b86}n

. Murray, Chisf, Facifities Radiological

~ If$

Date

Protection Section /

Inspection Summary

Inspection Conducted March 22-27,1987 (Report 50-313/87-06; 50-368/87-06)

Areas Inspected: Routine, unannounced inspection of the licensee's solid

radioactive waste management program and radioactive materials transportation

activities.

Results: Within the areas inspected, two violations were identified (failure

to comply with Technical Specifications (TS) for monitoring of radioactive

effluents and failure to perform appropriate airborne radioactive measurements,

see paragraph 5) and one deviation was identified (failure to comply with Final

Safety Analysis Report commitments, see paragraph 6).

DO

O

. m - . __ . . _.- _ _ _ - _ _ _ ._ - __ _ . _ . .. _.

,

[ ,

t

-2

DETAILS

1

1. Persons Contacted

AP&L

• S. M. Quennoz, General Manager Plant Operations

,

E. C. Ewing, General Manager Plant Support

T. C. Baker, Technical Support Manager

B. Baker, Operations Manager

E. E. Bickel, Health Physics (HP)' Superintendent

'

D. Howard, Special Projects Manager ,

D. B. Lomax, Plant Licensing Supervisor t

L. A. Taylor, Licensing Engineer

'

P.. Rogers,. Licensing Engineer

! *G. D. Provencher, Quality Assurance (QA) Supervisor

B. L. Bata, QA Engineer.

D. B. Lomax, Plant Licensing Supervisor

J. S..Fancher, HP Technician

-

B. C. Burchard, HP Supervisor

D. W. Akins, Radioactive Waste (Radwaste) Supervisor

'

H. N. Bishop, Assistant Radwaste Supervisor

W. L. Hada, HP Supervisor

D. L. Helm, HP Specialist (ALARA Coordinator)

! _J. Waid, Supervisor, Technical Specialist Training

l S. Burnett, HP Technician

l J. Cheatham, Radwaste Technician

-

D. D. Snellings, Nuclear Programs Manager

'

R. Davis, HP and Radwaste Trainer

J..Harrell, Radwaste Technician

, D. Plank, Radwaste Technician

'

G. Johnson, Assistant Store Supervisor

R. Gillespie, Technical Analyst Superintendent

' W. R. Pool, Assistant Radiochemistry Supervisor

Others

C. C. Harbuck, NRC Resident Inspector

S. Burrell, Contractor, Nuclear Pacific Packaging

Denotes those present at the exit interview on March 27, 1987.

2. Inspector Observations

i

The NRC inspector discussed the following observation with the licensee

- during the exit interview. This observation is neither a violation nor

unresolved item. The observation was identified for the licensee's

consideration for program improvement, but has no specific regulatory i

requirement. The licensee indicated that the item would be considered.

.

- -r eT*i----------* Pre-- - n w mm-ew--a--e**u-- s=*-~~-----r--*-we+v--e-e&c-e---g-y,-em*ww--vv--mm-,e-wwe=e=

, - .

3

.

Fire Alarm - The new radioactive waste storage building (RWSB) is

equipped with an internal fire alarm system that does not alarm in

either of the ANO reactor control rooms. The RWSB is not manned on a

24-hour basis.

3. Follow-up on Previous Inspection Findings

(Closed) Violation (313 and 368/8607-01): Failure to Verify Stability

of Solidified Radioactive Waste - This item involved the licensee's

failure to implement a program for assuring quality control of

solidification of contaminated oily waste. The licensee had revised ANO

operations Procedure 1603.017, " Solidification of Contaminated Oil," to

include the vendors procedure (PT-18, Revision 2) for processing and

testing of solidification samples for structural stability. The NRC

inspector reviewed the test results of solidification samples obtained

from batches of oily waste processed following the issuance of the

violation. This item is closed.

(0 pen) Violation (313/8631-01): Failure to Promptly Assess Airborne

Radioactive Material Uptakes by Personnel - This item involved the

licensee's failure to promptly evaluate survey data and assess airborne

radioactive material uptakes by personnel. The licensee had implemented a

revised procedure for expediently evaluating airborne radioactivity

surveys and identifying personnel with elevated exposures. The licensee's

new program will be further reviewed during the future inspections to

ensure that prompt assessments are performed. This item remains open

pending further NRC review.

4. Program Areas Inspected

The following program areas were inspected. Unless otherwise noted, the

inspection was completed, and revealed no violations, deviations,

unresolved items, or open items. Notations after a specific inspection

item are used to identify the following: I = item not inspected or only

partially inspected; V = violation; O = deviation; V = unresolved item;

and 0 = open item.

Inspection Procedure Inspection Requirements

83522 Radiation Protection, Plant

Chemistry, Radwaste, and

Environmental: Organization

and Management Controls

02.01 - Organization, Responsibilities,

and Authorities - I and 0

(see paragraph 7)

02.02 - Staffing - I

02.03 - Identification and Correction

of Weaknesses - I

02.04 - Audits and Appraisals - I

. . , ,

4

02.05 - Communication to Employees - I

02.06 - Documentation and Implementation - I

83722 Radiation Protection, Plant

Chemistry, and Radwaste: Organi-

zation and Management Controls

02.01 - Organization - I

02.02 - Staffing - I

02.03 - Radiation Protection Manager - I

02.04 - Identification and Correction

of Weaknesses - I

02.05 - Audits and Appraisals - I

83523 Radiation Protection, Plant Chemistry,

Radwaste, Transportation and Gnviron-

mental: Training and Qualifications

02.01 - Training and Qualifications

Program - I

02.02 - Education and Experience - I

02.03 - Adequacy - I

83723 Training and Qualifications: General

Em rloyee Training, Radiation Safety 2

Plant Chemistry, Radwaste, and

Transportation

02.01 - Training Adequacy - I

02.02 - Employee Knowledge Retention - I

02.03 - Transportation /Radwaste

Training - I

02.04 - Staff Qualification

Requirements - I

02.05 - Replacement Personnel - I

02.06 - Accreditation Status - I

02.07 - Audits and Appraisals - I

02.08 - Identify Training Not

Covered by Accreditation - I

84522 Solid Wastes

02.01 - Solid Waste System Construction

and Installation

02.02 - Liquid Leakage, Overflow, and

Spillage

i 02.03 - Sampling

02.04 - Test Program for Solid Waste

i

System

! 02.05 - Test Completion for Solid Waste

j System

1

_ _ _ - _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - _ _ _ _ - - - - _ _ _ _ - __ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

. . .

5

e

02.06 - Process Monitors

02.07 - Programs, Plans, and Procedures

for Solid Waste System

02.08 - Disposal of Low-Level Wastes

84722 Solid Wastes

02.01 - Audits and Appraisals

02.02 - Changes

02.03 - Processing and Storage

02.04 - Disposal of Low-Level Wastes

83726 Control of Radioactive Materials

and Contamination, surveys, and

Monitoring

02.01 - Audits and Appraisals - I

02.02 - Changes - I

02.03 - Surveys and Monitoring - I and V

(see paragraph 5)

02.04 - Radioactive Materials and

Contamination Controls - !

84524 Gaseous Waste System

02.01 - Construction and Installation - I

02.02 - Sampling - I

02.03 - Test Program - 1 '

02.04 - Test Completion - I

02.05 - Process and Effluent - V (see

paragraph 5)

02.06 - Programs, Plans, and

Procedures - 1

i 84850 Radioactive Waste Management -

~

Inspection o(~ Waste Generator i

khu~irementsofidCFFfDand

ID CPN~61

02.01 - Management Controls

02.02 - Quality Control (QC)

02.03 - Waste Manifests

02.04 - Waste Classification

02.05 - Waste Form and Characterization

02.06 - Waste Shipment Labeling

02.07 - Tracking of Waste Shipments

02.08 - Otsposal Site License Conditions

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _

o . .

6

65051 L.ow-Level Radioactive Waste Storage

Facilities

02.01 - Basis for Construction - 0 (see

paragraph 7)

! 02.02 - Quality Assurance

02.03 - Procedures for Construction

02.04 - Review of Construction - 0 (see

paragraph 6)

02.05 - Organization and Staffing

, 02.06 - Training and Qualifications

~

02.07 - Startup and Operations

Procedures

02.03 - Effluent Monitoring Changes

86721 Tran sportation  !

02.01 - Audits and Appraisals

02.02 - Procedures

02.03 - Procurement and Reuse of

Packagings

02.04 - Implementation

02.05 - Transportation Incidents

86740 Inspection of Transportation

Activities

'

02.01 - Management Controls

02.02 - Indoctrination and Training

Programs

02.03 - Audit Program

02.04 - Quality Assurance Program

02.05 - Procurement and Selection of

Packagings i

02.06 - Preparation of Packages for

Shipment

02.07 - Delivery of Competed Packages

to Carriers

02.08 - Receipt of Packages

02.09 - Periodic Maintenance of

Packagings

l

02.10 - Records and Reports

5. Violations ,

i

.

a. 83726,__ Item _02.03 - Surveys _and_ Mon _itoring

t

10 CFR Part 20.201(b) requires that licensee shall make or cause to

.

be made such surveys as: (1) may be necessary for the licensee to i

comply with the regulations in this part, and (2) are reasonable

under the circumstances to evaluate the extent of radiation hazards ,

l

. - _ _ _ _ _ _ _ - _ _ _ - - - _ _ _ - _ _ - _ _ -

_ _ - __--__ --__ _____ ___ -_

.. .

,

I

that may be present. As defined in 10 CFR Part 20.201(a), " survey"

means an evaluation of the radiation hazards incident to the

production, use, release, disposal or presence of radioactive

materials or other sources of radiation under a specific set of

conditions.

During the inspection of solid radioactive waste compaction

activities on March 24, 1987, the NRC inspector determined that the

licensee had not established a proper breathing zone survey program

to evaluate airborne concentrations for workers involved with

operation of the compactor. Part of the compaction process involves

workers reaching into the compactor to cut open plastic bags that

contain dry radioactive trash. The bags are cut open to release

trapped air before the bags are compacted. Openingthebagscould

create localized airborne concentrations within the worker s

breathing zone. The radiation work permit covering this work did not

require the workers to wear respiratory protection equipment or lapel

air samplers.

The opening of the plastic bags occurs insido the compactor which has

similarities to a chemistry laboratory fume hood (sliding door and

exhaust ventilation). When the worker reaches into the compactor,

the workers body above the waist is positioned inside the compactor,

which is maintained at a negative pressure with respect to the

surrounding area. Air samples are collected at locations outside the

compactor; however, these samples would not be representative of

airborne concentrations inside the compactor and in the workers

breathing zone.

The failure to perform proper airborne radioactivity monitoring of

workers is an apparent violation of 10 CFR Part 20.201(b).

(313/8706-01; 368/8706-01).

The NRC had previously brought to the attention of the licensee

deficiencies in their radioactivity monitoring and sampling program

(NRC Inspection Report 50-313/86-31 - Observation), and the licensee

had revised procedures to provide more emphasis in this area. The

NRC inspector also noted that the QA Department had made similar

observations concerning apparent deficiencies in airborne

radioactivity monitoring during a January 1987 QA surveillance of

radiological work activities,

b. 84524mitem_02.05 - Process and Effluent Monitors

Critorions 63 and 64 of Appendix A to 10 CFR Part 50 requires, in

part, that appropriate radioactive effluent monitors be provided for

the monitoring of effluent discharge paths from radioactive waste

systems.

_ - - - - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --- _ _

___,

,, .

8

l

Technical Specification (TS) 3.3.3.9, " Radioactive Gaseous Effluent

Monitoring Instrumentation," requires effluent monitoring

instrumentation to be operable during releases via the pathways set

forth in paragraph 6 ("Radwaste Storage Building HVAC Exhaust

System") of Table 3.3-12 of the TS. The TS Limiting Conditions for

Operations (LCOs) Action Statements 31 and 32 allow for the use of

auxiliary sampling equipment when the minimum number of channels

operable is less than that described in TS Table 3.3-12.

The licensee had initiated compaction of radioactive wastes using the

compaction system installed in the new Radioactive Waste Storage

Building (RWSB) on or about January 26, 1987. The licensee had

operated the compactor aoproximately 15 times as of this inspection.

The compactors self-contained filtered ventilation system discharges

to the RWSB's installed filtered ventilation system. Since the RWSB's

gaseous effluent monitoring system had not been installed, the

licensee had installed an auxiliary gaseous effluent sampling system.

This system is addressed in ANO Procedure 1603.032,

" Maintenance and Operation of the Container Products

Corporation (CPC) Compactor," Revision 1, dated January 22, 1987, and

is operated in accordance with TS 3.3.3.9 Action Statements 31 and

32.

During the inspection of compaction operations at the RWSB on

March 24, 1987, the NRC inspector determined that the auxiliary

sampling system could not collect representative samples of

particulate or iodine radioactivity due to the poor design of the

system and leaking mechanical joints upstream of the sample media

(filter and charcoal cartridge). Design deficiencies identified

included:

(1) Passing the gaseous effluent to be sampled through a variable

orifice flow regulating device, vacuum pump, water filter,

extensive plastic tubing, a sample flow measuring device

(rotometer), numerous mechanical joints, and a regulating valve

prior to collection on the sample media.

(2) The quantitative sample flow measuring device (rotometer) was

placed upstream of the sample media and due to the numerous

leakage points (outward) between the rotometer and the sample

media, accurate determination of the sample flow at the filter

media (TS 3.3.9 requirement) was unobtainable.

Due to sample leakage, plateout, and filtration in the system, a

representative sample could not be collected to evaluate the

radioactive effluents discharged via this path.

The NRC inspector noted that the licensee suspended further

compaction operations at the RWSB pending review of the gaseous

effluent discharge monitoring / sampling system.

.. .

9

,

This failure to implement adequate effluent sampling for the RWSB is an

apparent violation of TS 3.3.3.9. (368/8706-02)

6. Deviation

65051, Item 02.04, Review of Construction

ANO-2 FSAR Section 11.5.6 states that the RWSB will be equipped with

alarming area gamma radiation detectors and exhaust ventilation airborne

radioactivity monitors, high efficiency filters in the ventilation exhaust

system, and fire protection systems that include smoke / heat detectors, wet

pipe sprinkler, and an automatic deluge system.

The NRC inspector determined that the licensee had started moving packaged

and partially processed radioactive wastes into the RWSB on or about

November 1986, and started compacting radioactive wastes in the RWSB on or

about January 26, 1987. However, several systems that are described in

the FSAR had not been either installed, calibrated, or made operational as

noted below:

a. Gaseous Effluent Monitor: This system had not been installed. (See

paragraph 5 for related violation concerning effluent monitoring).

b. Area Radiation Monitors: This system had been installed, but not

calibrated,

c. Waste Compactor Exhaust Process Monitor: This system had been

installed, but not calibrated.

The failure to have the above systems installed, calibrated, and

operational prior to operation of the RWSB is an apparent deviation from

commitments made to the NRC. (368/8706-03)

The NRC inspector determined on March 27, 1987, that the fire protection

system had been installed, but facility operating personnel had not been

trained on its functions or operation.

7. Open Items

Open items are matters that require further review and evaluation by the

NRC inspector. Open items are used to document, track, and ensure

adequate follow-up on matters of concern to the inspector.

a. 83522, Item 02.01 - Organization, Responsibilities, and Authorities

The NRC inspector determined that the licensee had reorganized the

ANO Technical Support Department in mid-1986 and had removed the

radwaste group from under the HP superintendent's management. The

radwaste group now reports directly to the Technical Support

Department manager. The new organization is not shown in either the

..- .- .. - - . . - - - - _- . = - - . . - - . - . . -

.e*. .

10

.7

p&

TS'or the Final Safety Analysis Reports (FSARs) for either Unit 1 or

i

?- 2 at ANO. -This matter is considered an gpen item pending licensee

action to update the TS and FSAR. (313/870S-04; 368/8706-04)

,

4

b. 65051, Item 02.01, Basis for Construction

L ANO-2 FSAR Section 11.5.6, " Storage Facilities," states that the

design basis for the RWSB regarding radiation dose rates in office

areas and areas adjacent to the RWSB due to activities at the RWSB

are as follows:

1

Location Design Basis

,

RWSB.0ffice Space 0.5 millirem per hour (mrem /hr)

.

External to RWSB 0.8 mrem /hr

[ Beyond Site Boundary 0.9 mrem /yr

The NRC inspector determined that the licensee had placed

thermoluminescent dosimeters in the RWSB office spaces to verify

'

design criteria. However, a similar program had not been established

for areas external to the RWSB and beyond the site boundary.

'

,

, This matter is considered an open item pending licensee action to

establish a monitoring program to verify FSAR design criteria.

l (368/8706-05)

4

8. Exit Interview

.

1

The NRC inspector met with the licensee representatives denoted in

paragraph 1 on March 27, 1987. The NRC inspector summarized the scope and

findings of the inspection as presented in this report.

l

i

!

.

.

[