IR 05000313/1997017

Insp Repts 50-313/97-17 & 50-368/97-17 on 970825-28. Violations Noted.Major Areas Inspected:Routine,Announced Insp of Liquid & Gaseous Radioactive Effluent Waste Mgt Program Including Organization & Mgt Controls

ML20198J006
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198J002	List: IR 05000313/1997017 ML20198H998
References
50-313-97-17, 50-368-97-17, NUDOCS 9709230066
Download: ML20198J006 (20)

Text

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k ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.- 50-313 50 368 i

l License Nos., DPR-51 NPF-6 l

l Report N /97 17 1 50 368/97-17 Licensee: Entergy Operations, Inc.

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Facility: Arkansas Nuclear One, Units 1 and 2

! Location: Junction of Hwy 64W and Hwy.333 South Russellville, Arkansas Dates: August 25-28,1997 Inspector: Gilbert L. Guerra, Jr., Radiation Specialist Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENTS:

Attachment 1: Supplemental Information Attachment 2: Summary of Semi-annual Radioactive Waste Effluent Data

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9709230066 970917

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2-EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report 50 313/97-17: 50-368/97-17 A routine, announced inspection of the liquid and gaseous radioactive effluent waste management program including organization and management controls, radioactive effluent monitoring, and safety-related air cleaning systems was conducted.

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Plant Supoort

• A very good liquid and gaseous radioactive effluent waste management program was implemented. Goals for the reduction of radioactive effluent waste releases were established (Section R1.1).

• A very good safety-related air cleaning ventilation systems surveillance program was implemented (Section R1.2).

• The radiochemistry counting room was equipped with state-of-the-art analytical instrumentation. The liquid and gaseous radwaste systems were installed and operated properly (Section R2.1).

• Monthly surveillances of the post accidant sampling system were performed by qualified chemistry technicians (Section R2.21

• Allliquid and gaseous effluent radiation monitoring instrumentation was operable and properly maintained, tested, and calibrated (Section R2.3).

• Revisions to the offsite dose calculation manual were appropriately implemented ano documented (Section R3.1).

• Chemistry personnel had a very good understanding of the radioactive liquid and gaseous waste effluent management procedures, offsite dose calculation manual, and regulatory requiremmts (Section R4).

• Chemistry personnel participating in the radioactive effluent waste management program were properly trained and qualified (Section RS.1).

• The chemistry department organization and staffing met Technical Specification requirements and had experienced little change (Section R6.1).

• Quality assurance audits and surveillances of the radioactive effluent waste management program activities were technically comprehensive and provided excellent program evaluation and oversight (Section R7.1).

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l * Good semi annual radioactive effluent release reports were written and submitted in a timely manner and contained the required information (Section R8.1).

• The licensee effectively identified, tracked, and implemented corrective actions for any identified problems. A noncited violation was identified regarding the failure to perform an evaluation of an unmonitored release pathway (Section R8.2).

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-4-SeppfrLDetails Summary of Plant Status Units 1 and 2 were at power operations during the inspection. There were no operational occurrences that impacted the results of the inspectio IV. Plant Supp_grt R1 Radioactive Protection and Chemistry Controls R Radioloaical Waste Effluent Manaaement Pronrams Insoection Scoce (8475_Q1 The implementation of the radioactive effluent waste management program was reviewed. This review included: radioactive effluent waste processing; radioactive offluent waste sampling and analyses; analyses sensitivities and results; offsite dose results; and performance of required surveillance tests. The following activities were observed:

The collection of ventilation samples from the Unit 2 particulate, iodine, and noble gas monitors on August 26,1997, for analyses of particulates, iodine, and noble gases and preparation of release permits for these effluent release point *

The collection of a liquid waste sample from a boric acid condensate tank (2T69A) on August 27,1997, and performance of radiochemistry analyses on the sample and preparation of the release permit in preparation for discharg Qttervations and Findinas The inspector noted that licensee personnel followed the appropriate sampling, waste release permit preparation, discharge valve lineup, and radiation monitor setpoint calculation procedures during the observed tasks. The analyses of radioactive liquid and gaseous waste effluents and the approval and performance of waste discharges were conducted in accordance with licensee procedure Quantities of radionuclides released in the radioactive liquid and gaseo - waste effluents were within regulatory limits. Offsite doses were calculated acording to offsite dose calculation manual methodologies and were within regulatory limit Selected radioactive effluent waste release permits containing sample analyses for releases performed in 1996 and 1997 were reviewed and no problems were identifie . m y y sv. m y, w w , emur + : M,ia n P U VV Mi PVf@M/(

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5-The inspector noted that the licensee had established a task force for the review of radioactive r ffluent waste releases and associated problems in the effluent area.

] The task force identified numerous action items to improve the radioactive effluent waste systems and management program. Sito management has set goals for reducing the total amounts of liquid volume released, the curies released, and offsite dose The 1997,1998, and 1999 effluent release goals for Units 1 and 2, as compared to 1996 release data, are found in the following table. Data from the Arkansas E Nuclear One semi-annual radioactive effluent release reports is summarized in Attachment 2 to this repor Liquid Volume 2,204,142 1,800,000 1,450,000 1,250,000 Curies Discharged 1.32 1.50 1.20 0.80 Total Body Dose 0.19 One percent of

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Critical Organ Dose 0.26 The licensee had not made any major equipment or design modifications to the radioactive liquid waste management systems since the last NRC inspection of this area in January 199 Conclusion A very good liquid and gaseous radioactive effluent waste management program was implemented. Quantities of radionuclides released and offsite doses to the environment, calculated using offsite dose calculation manual methodologies, were within regulatory limits. Goals for the reduction of radioactive effluent waste releases were established. No major equipment or design modifications were made to the radioactive liquid and gaseous waste management system R1.2 Ennineered Safetv Feature Filtration and Control Room Habitability Systems Jaspection Scone (84750)

Surveillance and test results for the safety-related air cleaning ventilation systems testing program were reviewed to determine agreement with the commitments in the Updated Safety Analysis Report and compliance with the requirements in the Technical Specifications. The inspector also observed in-place filter testing of the Unit 1 and Unit 2 spent fuel pool ventilation filtration system l

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e 6 Observations and Findinas The inspector and the system engineer performed a visual inspection of all the Arkansas Nuclear One Technical Specification-required ventilation filtration system The systems observed included those for the fuel handling areas, control rooms, reactor building purge, penetration rooms, and the auxiliary building. These systems contained high efficiency particulate air filters and activated charcoa!

adsorbers. No problems were identified during the visual inspection of the ventilation filtration systems. No external damage to the filtration units was identified. All filter housings and ducts were well maintained. The areas surrounding the filtration units were clean, free of debris, and the filtration units were adequately lighted inside and outside to provide for visual inspection of housings and component .

The in-place filtei testing of the Unit 1 and Unit 2 spent fuel pool ventilation filtration system filters was performed in accordance with licensee procedures and Technical Specification requirements. Air cleaning system surveillance procedures incorporated guidance from ANSI 510-1975, " Standard for Testing of Nuclear Air Cleaning Systems."

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The licensee's surveillance testing program included the required periodic functional checking of the safety-related air cleaning ventilation systems' components, evaluation of the high efficiency particulate air filters and activated charcoal adsorbers, and in-place filter testing of the ventilation system filters. Since some of the surveillance tests were only required to be performed at 18-month frequencies, the inspector verified that the previous two surveillance tests were performed, as required, at the 18 month frequency. The activated charcoal efficiency tests were performed by an offsite contract laborator The inspector noted that the Technical Specification requirement for testing the various air cleaning ventilation systems' activated charcoal adsorber material after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation following previous laboratory testing was tracked by a surveillance performed by the system engineer on a monthly basis during normal operations and on a weekly basis during outages, Conclusion A very good safety-related air cleaning ventilation systems surveillance program was implemented and conformed to the commitments in the Updated Final Safety Analysis Report and met Technical Specification requirements. The safety-related air cleaning systems test results were within Technical Specification limit l

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7-R2 Status of Radiological Protection and Chemistry Facilities and Equipment R Radiochemistry Countina Room inspection Scope (84750)

The inspector reviewed operations in the radiochemistry counting room and visually inspected the Arkansas Neclear One radwaste process systems, Observations and Findingj The radiochemistry counting room maintained state-of-the-art analytical instrumentation to perform the required radiochemistry analytical measurements of the radioactive effluent wastes. Instrumentation was operable and well maintaine Chemistry technicians assigned to the radiochemistry counting room were knowledgeable on the use of the instrumentatio The liquid and gaseous radwaste processing and storage systems were installed as described in tha Updated Safety Analysis Report and were operated in accordance with station procedures, Conclusion The radiochemistry counting room was equipped with state-of-the-art analytical instrumentation to perform the required analyses. Liquid and gaseous radwaste systems were installed and operated properl R2.2 Post Accident Samplina Svstem l Inspection Scone (847501 Surveillance programs for the post accident sampling system instrumentation were reviewed, Observations and Finding l The inspector noted that post-accident sampling system samples were obtained I monthly. The monthly surveillances for testing the sampling capabilities of the post-l accident sampling system were perft rmed by chemistry technicians. Ten chemistry l technicians were qualified and traineJ on the use of the post accident sampling system. These chemistry technicians were required to perform this surveillance on one of the systems at least once oer year; most performed this surveillance more than once since 24 surveillances would be performed during one year for both unit .

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-8- Conclusing Monthly surveillances of the post-accident sampling system were performed by ,

qualified chemistry technician l R2.3 Liauid andSc.seous Effluent Radiation Monitors Insoection Snoce (84750)

The liquid and gaseous effluent radiation monitors were inspected for operation, calibration, and reliabilit ObservationLand Findingi Calibration records of liquid and gaseous effluent radiation monitors confirmed that the calibrations had been performed at the required intervals. These records indicated that the liquid and gaseous radioactive effluent waste monitoring instrumentation was properly maintained, tested, and calibrated in agreement with the surveillance requirements specified in the Technical Specification The licensee had experienced some problems with its particulate, iodine, and noble gas monitors. In response, the licensee made readily available alternate monitoring and sampling methods for each of its particulate, iodine, and noble gas monitors to l l

be able to meet Technical Specification limiting condition for operation

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requirement Conclusion Allliquid and gaseous effluent radiation monitoring instrumentation was operable and properly maintained, tested, and calibrated in compliance with the surveillance requirements in Technical Specification R3 Radiological Protection and Chemistry Procedures and Documentation R 3.1 Chances to the Offsite Dose Calculation Manual and Procedures Insoection Scone (84750)

Revisions to the offsite dose calculation manual were reviewed for any changes to the radioactive effluent waste programs and the radwaste system design and operation, including the performance of proper 10 CFR 50.59 review . - . _ _ - .- _--- .- .- - .. . _= -_ - - - ..

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d-9-l Observations and Findings

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, The radioactive efflu waste program's iinplementing procedures described the responsibilities for col. ' tion and analyses of liquid and gaseous radioactive effluent

waste samples. Procedures governing radioactive effluent waste releases contained

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sufficient detail and were comprehensive. These procedures provided for the following: sampling of the radioactive liquid and gaseous wastes; radionuclide analyses prior to release; calculation of effluent radiation monitor setpoints,

! projected offsite radionuclide concentrations, and offsite doses prior to release. No

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concerns were identified with the licensee's sample collection procedure Changes to the offsite dose calculation manual were made. Revisions 7 and 8 were issued since the last NRC inspection. The inspector deterrnined that the changes did not reduce the effectiveness of the radioactive effluent waste management program.

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The changes were documented in the appropriate Semi-annual Radioactive Effluent Release Reports as required by Technical Specifications.

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l Revisions to the offsite dose calculation manual were appropriately implemented and documente R4 Staff Knowledge and Performance 4 Insoection Scone (84750)

Discussions were held with chemistry department personnel to evaluate their

. knowledge and performance of chemistry activities, Observations a_qd Findinas

' The inspector observed chemistry technicians perform some of their duties and responsibilities for implementation of the radioactive effluent waste programs and determined that they were f amiliar with the requirements of the radioactive ef fluent i waste programs. Chemistry personnel including supervisors and technicians were knowledgeable of the liquid and gaseous waste effluent management procedures, offsite dose calculation manual requirements, and regulatory requirements and maintained a high level of performanc Conclusion i

Chemistry personnel had a very good understanding of the radioactive liquid and gaseous waste effluent management procedures, offsite dose calculation manual, and regulatory requirements.

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R5 Staff Training and Qualification R S.1 Trainina and Qualification of Chemistry Personngl !nsoection Scoce (84750)

Training and qualifications for chemistry technicians involved with conducting the radioactive effluent waste management programs were reviewed, Oh12rvations and Findinas Using computerized training records of qualification tasks completed, the inspector verified that a high percentage of the personnel in the chemistry department were qualified to perform routine radioactive waste management program activitie Three new chemistry technicians were working toward completing the appropriate task qualification The inspector observed chemistry personnel performing assigned tasks and noted that they were knowledgeable and performed well. The inspector concluded that these individuals were properly qualifie The inspector determined that proper training and qualification programs were being implemented for chemistry technician Conclusiorj Chemistry personnel participating in the radioactive effluent waste management program were properly trained and qualifie R6 Radiological Protection and Chemistry Organization and Administration R Oraanization and Staffina g Insoection Scoce (84750)

The organization, staffing, and assignment of the radioactive effluent waste management program responsibilities were reviewe Observations and Findinas i

The inspector verified that the organizational structure of the chemistry department, which was responsible for the implementation of the radioactive effluent waste programs, was as defined in the Update Final Safety Analysis Report and Technical Specifications. The chemistry department was assigned the responsibility for preparing radioactive waste release permits, evaluating the radioactive effluent waste releases, calculating the radiation doses resulting from the releases to the

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- 13-Summaries of the quantities of radioactive liquid and gaseous effluents released the environment, and their associated doses to members of the public for 1995 a 1996, were properly documented in the semi annual reports. A summary of the radioactive liquid and gaseous effluent re! eases and associated doses is presente Attachment 2 to this repor The semi annual reports included changes to the offsite dose calculation manual require Conclusiqa Good Semi-annual Radioactive Effluent Release Reports were submitted in a time manner and contained the required information presented in the required forma R8.2 Effluent issues Insoection Scooe (84750)

The inspector evaluated the effectiveness of the licensee's controls in identifying resolving, and preventing problems in the area of radwaste treatment and effluen monitoring, based on issues, events, or problems identified though the licensee's condition reporting syste Observations and Findinos Through the review of condition reports the inspector identified that the licensee had discovered two unmonitored release pathways from the Arkansas Nuclear O site. One unmonitored release pathway identified was from the condensate demineralizer system. The licensee found that when waste water is transferred

_ from condensate demineralizer resin storage tank T-56 to polisher vessel T-54 following demineralizer regeneration, the waste water is diverted directly to the circulation water discharge fiume creating an unmonitored release pathway. Thi situation was discovered on January 27,1997. The licensee's investigation revealed that this situation has existed since about 1980, when the licensee first experienced primary to secondary leakage causing the secondary side effluent to

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become contaminated. The licensee took proper corrective actions including:

determining the radioactivity involved and tl.e volume of liquid released, evaluat offsite doses, and revising the appropriate procedure to require a release permit when conducting these operations. The licensee determined that releases of thi type are performed on an average of twice per week with approximately 2500 gallons per release being discharged. The detectable tritium activity has been a 1 E-5 microcuries per milliliter level and the contribution to offsite doses has be the 2 E-10 millirem leve __

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The second unmonitored release pathway was discovered on March 19,1997, when an auxiliary operator noted that there were 2-3 drops per minute draining from a main steam line steam trap drain into a floor drain marked as contaminated located in Area 40 of the Unit 1 turbine building. The licensee's investigation determined that drains in Areas 40 and 41 of the Unit 1 turbine building discharged directly to the circulation water discharge fiume which created an unmonitored release pathway from the Arkansas Nuclear One site. Corrective actions taken by the lic 4nsee included: stopping the leak, marking the drains with identification that they discharge as unmonitored releases, revising site drawings as appropriate, investigating other drains in both units, and evaluating reconfiguring the drain However, no evaluation was performed to determine the offsite dose consequences to members of the public due to releases or future potential releases and whether release concentrations were within regulatory limit CFR 20.1302(a) states that the licensee shall make or cause to be made, as appropriaM, surveys [ evaluation (10 CFR 20.1003)) of radiction levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10 CFR 20.1301. 10 CFR 20.1302(b) states that a licensee shall show compliance with the annual dose limit in 10 CFR 20.1301 by demonstrating by measurement or calculation that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or demonstrating that the annual average concentrations of radioactive material released in gaseous and liquid effluents at the boundary of the unrestricted area do not exceed the values specified in Table 2 of Appendix B to Part 20; and if an individual were continuously present in an unrestricted area, the dose from external sources would not exceed 0.002 rem in an hour and 0.05 rem in a yea On August 28,1997, the licensee issued Condition Report 97-1-0245 and performed an evaluation to determine the offsite dose consequences to members of the public and activity concentrations. This condition report was transmitted to the inspector on September 3,1997. The licensee concluded that releases though this release pathway vsere minute. Sample activity from condensate pump discharges are approximately 4 E-4 m;crocuries per milliliter. Approximately 8,150,00 gallons would have to be released through this pathway in 6 months to be a significant contributor to offsite doses as defined in NRC Regulatory Guide 1.109, " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1." The inspector found that the licensee's response, corrective actions, and evaluation of the above item were appropriat _ -. _ _ _ _ _ _ _

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-15-Due to the m5ute dose consequences for releases through this pathway and the corrective actions that have been implemented, the failure to perform an evaluation as required by 10 CFR 20.1302(a) constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (50-313:368/9717-01).

c. Concipji2D The licensee effectively identified, tracked, and implemented corrective actions for any identified problems. A noncited violation was identified regarding the failure to perform an evaluation of an unmonitored release pathwa V. Management Meetings X1 Exit Meeting Summary The inspector presented the results of the inspection to members of licensee management at the conclusion of the inspection on August 28,1997. The licensee acknowledged the findings presented. No proprietary information was identifie t

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SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. Bement, Manager, Radiation Protection and Chemistry M. Cooper, Licensing Specialist W. McKelvy, Chemistry Superintendent D. Mims, Licensing Director M. Paterak, Air Cleaning Systems Engineer G. Stephenson, Chemistry Specialist R. Edington, General Manager G. Ashley, Licensing Supervisor R. Buckley, Senior Staff Coordinator D. Calloway, Environmental Specialist M. Frala, Chemistry Supervisor C. Zimmerman, Unit 1 Plant Manager R. McCormick, Quality Assurance, Lead Auditor T. Mitchell, Unit 1 System Engineering Manager R. Partridge, Chemistry Technical Support Supervisor J. Vandergrift, Quality Assurance Director NRC S, Burton, Resident inspector J. Melfi, Resident inspector LIST OF INSPECTION PROCEDURES USED IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEM OPENED AND CLOSED Opened 50-313:-368/9717-01 NCV Failure to perform an evaluation as required by 10 CFR 20.1302(a)

Closed E.0 313;-368/9717-01 NCV Failure to perform an evaluation as required by 10 CFR 20.1302(a)

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LIST OF DOCUMENTS REVIEWED PROCEDUf31S 2607.010 Sampling the Unit 2 Vents, Revision 9 2007.023 Sampling the Boric Acid Condensate Tanks (2T 69A/B), Revision 4 1607.009 Sampling the Treated Waste Monitor Tanks (T 16A/B), Revision 10 1604.017 Analysis of Liquid Waste, Revision 16 1604.015 Analysis of Unit Vents, Revision 13 5120.420 Ventilation Filtration System Run Time Surveillance, Revision 1 AUDITS AND SURVEILLANCES OAP 28-96 Environmental Monitoring, May 2,1996 QAP-22-96 1996 Chemistry and Radiochemistry Audit, November 5,1996 SR-012 96 Chemistry Procedure Viability, July 12,1996 SR 034 97 Chemistry Job Observation Program, July 24,1997 ,

SR-010 97 SPING Failures, March 11,1997 Vendor Audits REPORTS Semi Annual Radioactive Effluent Release Reports for 1995,1996,1997 OTHER Condition Reports 197-0095, 2 96 0168,1-96-0321, 2 97 0037, C 96-0029, C 96 0135 Of fsite Dose Calculation Manual, Revision 8 Chemistry Department Training Records Organizational Charts Air Cleaning Systems Surveillance Test Records

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