IR 05000313/1986007

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

ML20205N747
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/10/1986
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205N734	List: ML20205N731 ML20205N740 ML20205N747
References
50-313-86-07, 50-313-86-7, 50-368-86-07, 50-368-86-7, NUDOCS 8605020280
Download: ML20205N747 (8)

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APPENDIX B U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC. Inspection Report: 50-313/86-07 Licenses: _DPR-51-50-368/86-07 NPF-6 Licensee: Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One (ANO), Units 1 and 2 Inspection At: ANO Site, Pope County, Russellville, Arkanst Inspection Conducted: March 17-21, 1986 Inspector: n[ m M & M 4/ /hh on Specialist, Facilities Date f.@,R.Radiological E. Baer, Padiat'

Protection Section

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Approved: d ,h4144tttLi Yl0hkb 8.Murray, Chief, Faci /itiesRadiological ITate '

Protection Section Inspection Summary Inspection Conducted March 17-21, 1986 (Report 50-313/86-07; 50-368/86-07)

Areas Inspected: Routine, unannounced inspection of the licensee's radioactive material transportation program, low-level radioactive waste storage facility, and solid radioactive waste managemen Results: Within the areas inspected, one violation was identified (failure to verify stability of solid radioactive waste, see paragraph 7). No deviations were identifled, f

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DETAILS Persons Contacted

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i l *J. M. Levine, Director, Site Nuclear Operations D. W. Akins, Radioactive Waste Supervisor B. L. Bata, Quality Assurance (QA) Engineer H. N. Bishop, Radioactive Waste Assistant Supervisor

! *M. J. Bolanis, Health Physics (HP) Superintendent

' *P. L. Campbell, Plant Licensing Engineer J. W. Cheatham, Radioactive Waste Technician R. M. Copp, QA Engineer J. D. Deal, HP/Radwaste Trainer

"E. C. Ewing, General Manager, Plant Support G. L. Fiser, Radiation Chemistry Supervisor S. Forrest, Radioactive Waste Technician

• L. W. Humphrey, General Manager, Nuclear Quality l *D. B. Lomax, Plant Licensing Supervisor l W. C. McCorp, Quality Control (QC) Supervisor

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A. M. McCullah, Radioactive Waste Technician W. R. Pool, Assistant Radiation Chemistry Supervisor

*G. D. Provencher, QA Supervisor

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• D. Rispoli, Fire Protection Specialist S. P. Rcbinson, Radioactive Waste Assistant Supervisor T. M. Rolniak, HP/Radwaste Lead Trainer

• E. L. Sanders, Maintenance Manager

• L. W. Schempp, QC Superintendent

• C, N. Shively, Plant Engineering Superintendent D. D. Snellings, Nuclear Programs Manager

• A. Storey, Safety and Fire Prevention Coordinator l Others S. S. Burrell, Radwaste Operator, NuPac Services In C. R. Fellhauer, Director, Customer Services, NuPac Services In *C. C. Harbuck, Resident Reactor Inspector, USNRC

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• E. Murphy, Project Inspector, USNRC l

l The NRC inspector also interviewed several other licensee employees l including HP, chemistry, maintenance, and training personne * Denotes those present at the exit interview on March 21, 198 . Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit interview on March 21, 1986. These observations are neither violations nor unresolved items.

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These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that these items would be reviewed: Low-level Radioactive Waste Storage Facility - The Updated Safety Analysis Report (USAR) had not been revised to include the low-level radioactive waste storage facility. See paragraph 3 for additional detail Radioactive Waste Volume Reduction Program - A radioactive waste volume reduction program had not been established to reduce the volume of waste to the licensee's projected volume. See paragraph 3 for additional detail Position Descriptions for Radwaste Personnel - The present position descriptions f1r radwaste personnel do not accurately reflect the duties and responsibilities of the position. See paragraph 5 for ar.ditional detail . Low-Level Radioactive Waste Storage Facility The NRC inspector reviewed the status of the onsite low-level radioactive waste (LLRW) storage facility for compliance with facility license coaditions and the recommendations of NRC Generic letter 81-38, NRC Office of Inspection and Enforcement (I&E) Circular 80-18, NRC Regulatory Guide (RG) 1.143 and NUREG 080 The NRC inspector determined that the licensee had completed construction of an onsite LLRW facility as previously described in NRC Inspection Reports 50-368/84-19 and 50-368/85-08. The licensee's projected completion date is September 1986 for the facility to be fully operationa The NRC inspector discussed with licensee representatives the need to revise the USAR for both units to address the LLRW facility describing the purpose, capability, and cperation. The NRC inspector also reviewed the licensee correspondence to the NRC dated February 25, 1985, which stated that the total annual generation of LLRW for ANO is estimated to be approximately 24,000 cubic feet. A review of previous LLRW shipments indicated volumes of: 1985 - 25360 cubic feet, 1984 - 33110 cubic feet, 1983 - 25000 cubic feet, ar.d 1982 - 32,500 cubic fee The NRC inspector noted that the licensee would need to implement an aggressive radwaste volume reduction program to achieve a goal of 24000 cubic feet per year. The licensee indicated an awareness of the need to reduce LLRW volume No violations or deviations were identifie . Waste Generator Requirements 10 CFR 20 and 10 CFR 61 - The NRC inspector reviewed the licensee's program for disposal of LLRW to determine compliance with the requirements to 10 CFR Part 20.311 and 10 CFR Parts 61.55 and 61.5 The NRC inspector reviewed the licensee's LLRW program for generation of waste manifests, waste classification, waste form and characterization, labeling, tracking of waste shipments, and maintaining a current copy of the

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disposal site license condition The licensee was currently implementing a LLRW program as described in NRC Inspection Report 50-368/84-1 The NRC inspector determined that the licensee had solidified low-level contaminated lubricating oils (approximately 12,000 gallons) in 608 55 gallon containers in accordance with station procedure 1603.017,

" Solidification of Contaminated Oil," Revision 0, March 14, 1985, which incorporated the vendor's procedure OH-19, " Operating Procedure for Oil Solidification System," Revisioa 1, February 22, 1985. The NRC inspector noted that the vendor's procedure did not require that samples be collected and analyzed to demonstrate a free standing monolith is obtained although Section 7.9 of procedure OM-19 requires that the final product be inspected to verify that the waste is in a solid form. The vendor's procedure references PT-18, " Process Control Program for NVPAC Oil Solidification System," Revision 0, February 22, 1985. The NRC inspector requested from the licensee and vendor representatives onsite a copy of PT-18, but neither the licensee nor the vendor had a copy of the procedur CFR Part 20.311(d)(3) requires that any generating licensee who transfers radioactive waste to a land disposal facility shall conduct a quality control program to assure compliance with paragraphs 61.55 and 61.56 of this chapte The NRC inspector stated that failure to have controlled copies of vendor procedures and complete a successful sample solidification verification to demonstrate compliance with 10CFR Part 61.56 is considered a violation of 10 CFR 20.311(d)(3) (313/8607-01 and 368/8607-01). Organization and Management Controls The NRC inspector reviewed the licensee's radicactive waste organization and management controls to verify agreement with AN0's Technical Specifications (TS) and USA t The NRC inspector determined that the licensee's radioactive vaste management program is a separate section in the health physics grou However, TS Figure 6.2-2 does not identify the radwaste group as a separate section. The Radioactive Waste Supervisor reports to the Health Physics Superintendent and has two Radioactive Waste Assistant Supervisors that report to hi The NRC inspector reviewed the position description for the three radioactive waste supervisory positions, positions 0461.0, 0462.0, and 0463.0 and noted that tiese position descriptions, revised and approved in December 1953, did not include all the responsibilities that are currently required of the position including waste tracking methods, waste form and characteristic determinations, and computer operations. The licensee did not have position descriptions for the technicians assigned to decontamination and radwaste duties, rather a position task analysis for a health physicist / apprentic _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ - - _ _ _ - _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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

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

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100 percent in two years, that exists in this sectio No violations or deviations were identified.

l 6. Training and Qualifications

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The NRC inspector reviewed the training and qualifications of personnel l assigned to the radioactive waste section to determine compliance with '

licensee commitments to I&E Bulletin 79-19 and the requirements of 40 CFR 173.1(b).

The NRC inspector interviewed personnel responsible for radioactive material transportation activities, reviewed the health physics training outlines and ;

select lesson plaas. The NRC inspector noted that a vendor had presented a l course onsite which included the Department of Transportation (DOT)

requirements and burial site restriction No violations or deviations were identified.

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7. Solid Waste Management The NRC inspectur reviewed the licensee's solid radioactive waste management program for compliance with TS Section 6.8.1 for both units and commitments contained in USAR Section 11.1.3.3 for Unit 1 and Section 11.5 for Unit The NRC inspector reviewed procedure 1012.003, " Solid Radioactive Waste Management Process Control Program for Arkansas Nuclear One Units 1 and 2,"

Revision 0, March 28, 1984, and Attachment A which contains the Process Control Program (PCP). The NRC inspector noted that the PCP,Section III, addresses oily waste and states that this type of waste will be processed in accordance with approved plant procedure The NRC inspector discussed with licensee representatives that oily waste is considered wet waste and the criteria contained in Section II of the PCP " Wet Waste" would also apply to oily wast The NRC inspector had previously determined, see paragraph 4 of this report, that the approved plant procedures did not include all the critical elements necessary to comply with Federal Regulations. The licensee indicated they would review this section of the PC The NRC inspector also discussed the USAR solid radioactive waste sections for both units with the licensee. Neither Units 1 nor 2 USARs addressed the capability for vendor solidification system The licensee stated that these sections of the USAR had been completely revised and would be submitted in the next USAR updat No violations or deviations were identifie . Audits The NRC inspector reviewed the licensee's last audit performed QAP-3-85

" Operating Plant Surveillance Audit Health Physics /Radwaste Management"

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during the period December 20, 1985 through January 31, 1986. The NRC inspector also reviewed Quality Control (QC) surveillances,85-006, 85-031,85-068, 85-295,85-296, 85-297,85-305, 85-319,85-385, and 85-405. The NRC inspector noted that several shipping activities which would normally have been observed by QC on QC checklist 85-405 had been completed by the radwaste group prior to QC being notified of the shipment. The eadwaste section routinely notifies QC of each shipment and QC will selectively perform surveillances. The NRC inspector determined that both QA and QC personnel had attended a course on transportation regulatory requirements, No violations or deviations were identifie . Transportation Activities The NRC inspector reviewed the licensee's transportation program to determine compliance with 10 CFR Parts 20 and 71, and DOT regulations 49 CFR Parts 170-18 Quality Assurance Program The NRC inspector determined that the licensee had submitted a QA program for approval to the NRC to comply with 10 CFR Part 71, Subpart H. The licensee had received NRC Form 311, Quality Assurance Program Approval, approval number 0341, Revision 2, dated January 23, 198 Procurement and Selection of Packaging The NRC inspector reviewed the licensee's program for procurement and selection of packaging against the requirements of.10 CFR Part 71.12 and 71.54 and 49 CFR Part 17 The NRC inspector reviewed the licensee's procurement of 00T and NRC certified packaging. The licensee had available the appropriate documentation on design, use, maintenance, testing, and NRC/00T certification, Preparation of Packages for Shipment The NRC inspector reviewed the licensee's program for preparation of packages for shipment to determine compliance with the requirements of 10 CFR Parts 20.311, 71.12, and 49 CFR Parts 172 and 17 The licensee routinely used a checkoff list to assure that procedures were followed and that packages were properly prepared in accordance with DOT, state and burial site requirement ,

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, 7 Delivery of Completed Packages to Carrier The NRC inspector reviewed the licensee's program for delivery of completed packages to a carrier for transport to determine compliance with 10 CFR Parts 20.311, 71.55 and 49 CFR Parts 170 to 17 The NRC inspector observed the licensee preparing, loading, labeling, placarding, surveying, and completing shipping documentation for a van loaded with Low Specific Activity (LSA) boxes containing radioactively contaminated laundr Receipt of Packages The NRC inspector reviewed the licensee's program for receipt of packages containing radioactive material to determine compliance with 10 CFR Part 20.20 The licensee's activities for receipt of radioactive material are governed by procedure 1622.021, " Radioactive Equipment Receipt, Storage, and Accountability," Revision 2, June 12, 1985. The NRC inspector reviewed this procedure for consistency with regulatory requirements and to determine whether it covered all aspects of the work being performe Records, Reports, and Notifications The NRC inspector reviewed selected records of 22 radioactive material shipments of the 149 shipments made by the licensee during calendar year 1985 and all 7 shipments made during period January 1 through February 1,1986, for compliance with the requirements of 10 CFR Parts 20.311 and 71.62. The licensee maintained records of all radio-active material shipments as required. The records were complete with all shipping documentation, including the receipt and shipping radiation survey dat The NRC inspector reviewed the licensee's procedures for the radioactive material handling and shipping program as contained in Attachment No violations or deviations were identifie . Exit Interview The NRC inspector met with the NRC resident inspector and licensee representatives denoted in paragraph 1 at the conclusion of the inspection on March 21, 1986. The NRC inspector summarized the scope and findings of this inspection, including the observations identified in paragraph The licensee stated that they would not solidify any contaminated oily waste until a quality control program was inplace and implementing i

procedures available to assure structural stability of the waste for t

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ATTACHMENT 1

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

I 1012.003, Solid Radioactive Waste Management Process Control Program for ANO Units 1 and 2, Revision 0, March 28, 1984, t

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

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1603.004, Curie Content of Radioactive Waste Containers, Revision 4, February 1, 198 .006, Disposal of Spent Radioactive Resin, Revision 6, August 7, 198 .008, Guidelines for Classification and Marking of Radioactive Waste Containers, Revision 3, October 31, 198 .011, Segregation of Radioactive Waste, Revision 3, April 22, 198 .012, Maintenance and Operation of the Nupactor Waste Compactor, Revision 4, October 10, 198 .013, Operation of the Consolidated Balling Machine Waste Compactor,-

Revision 4, October 10, 198 .014, Packaging of Non-Compactable Radioactive Waste, Revision 5, December 12, 198 .015, Radioactive Waste Management Program Surveillances, Revision 2, l January 30, 198 .016, Encapsulation of Radioactive Waste, Revision 1, PC-1, May 24, 198 l 1603.017, Solidification of Contaminated Oil, Revision 0, March 14, 198 ., .. -. .

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