ML20214S554
| 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: |
| 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
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APPENDIX C
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-313/87-05
Licenses: DPR-51
50-368/87-06
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
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Inspector:
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H. Chaney, RidiAtton Specialist, facilities
Dats
Radiological Protection Section
Approved:
/]AOhl)b86}n
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. Murray, Chisf, Facifities Radiological
Date
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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).
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DETAILS
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1.
Persons Contacted
- S. M. Quennoz, General Manager Plant Operations
E. C. Ewing, General Manager Plant Support
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- T. C. Baker, Technical Support Manager
B. Baker, Operations Manager
E. E. Bickel, Health Physics (HP)' Superintendent
D. Howard, Special Projects Manager
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D. B. Lomax, Plant Licensing Supervisor
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L. A. Taylor, Licensing Engineer
P.. Rogers,. Licensing Engineer
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- 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
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D. W. Akins, Radioactive Waste (Radwaste) Supervisor
H. N. Bishop, Assistant Radwaste Supervisor
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W. L. Hada, HP Supervisor
D. L. Helm, HP Specialist (ALARA Coordinator)
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_J. Waid, Supervisor, Technical Specialist Training
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S. Burnett, HP Technician
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J. Cheatham, Radwaste Technician
D. D. Snellings, Nuclear Programs Manager
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R. Davis, HP and Radwaste Trainer
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J..Harrell, Radwaste Technician
D. Plank, Radwaste Technician
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G. Johnson, Assistant Store Supervisor
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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
The NRC inspector discussed the following observation with the licensee
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during the exit interview. This observation is neither a violation nor
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unresolved item.
The observation was identified for the licensee's
consideration for program improvement, but has no specific regulatory
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requirement. The licensee indicated that the item would be considered.
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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
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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
E rloyee Training, Radiation Safety 2
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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
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02.03 - Sampling
02.04 - Test Program for Solid Waste
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02.05 - Test Completion for Solid Waste
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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
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02.04 - Test Completion - I
02.05 - Process and Effluent - V (see
paragraph 5)
02.06 - Programs, Plans, and
Procedures - 1
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84850
Radioactive Waste Management -
Inspection o(~ Waste Generator
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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
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65051
L.ow-Level Radioactive Waste Storage
Facilities
02.01 - Basis for Construction - 0 (see
paragraph 7)
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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
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02.07 - Startup and Operations
Procedures
02.03 - Effluent Monitoring Changes
86721
Tran sportation
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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
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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
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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
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02.10 - Records and Reports
5.
Violations
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a.
83726,__ Item _02.03 - Surveys _and_ Mon _itoring
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10 CFR Part 20.201(b) requires that licensee shall make or cause to
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be made such surveys as:
(1) may be necessary for the licensee to
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comply with the regulations in this part, and (2) are reasonable
under the circumstances to evaluate the extent of radiation hazards
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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.
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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.
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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
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TS'or the Final Safety Analysis Reports (FSARs) for either Unit 1 or
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2 at ANO. -This matter is considered an gpen item pending licensee
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action to update the TS and FSAR. (313/870S-04; 368/8706-04)
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b.
65051, Item 02.01, Basis for Construction
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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:
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Location
Design Basis
RWSB.0ffice Space
0.5 millirem per hour (mrem /hr)
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External to RWSB
0.8 mrem /hr
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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
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for areas external to the RWSB and beyond the site boundary.
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This matter is considered an open item pending licensee action to
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establish a monitoring program to verify FSAR design criteria.
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(368/8706-05)
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8.
Exit Interview
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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.
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