IR 05000298/1988012
| ML20154S610 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/27/1988 |
| From: | Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154S607 | List: |
| References | |
| 50-298-88-12, NUDOCS 8806090110 | |
| Download: ML20154S610 (13) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION RE'3 ION IV NRC Inspection Report:
50-258/88-12 Operating License:
DPR-46 Decket:
50-298 Licensee:
Nebraska Public Power District (NPPD)
P. 0 Box 499 Columbus, NE 68601 Facility Name:
Cooper Nuclear Station (CNS)
Inspection At:
CNS Site, Brownville, Nebraska Inspection Conducted:
April 25-29, 1988 7/Pr Inspector:
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- . B. Nicholas, Senior Radiation Specialist Fate M acilities Radiation Protection Section l
Approved:
l R".
E. Baer, Acting Chief, Facilities Date Radiological Protection Section Inspectio' Summary Inspection Conducted April 25-29, 1988 (Report 50-298/88-12)
Areas Inspected:
Routine, unannounced inspection of the licensee's liquid and gaseous radioactive waste management programs.
Results: Within the areas inspected, no viclations or deviations were identified.
8806090110 880601 PDR ADOCK 05000298 o
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2 DETAILS 1.
Persons Contacted NPPD
- G. R. Horn, Division Manager, Nuclear Operations
- L. E. Bray, Regulatory Compliance Specialist
- R. Brungardt, Operations Manager
- K. L. Fike, Chemist R. L. Gibson, Quality Assurance (QA) Engineer L. T. Guenther, Mechanical Engineer
- R. J. Mcdonald, Chemistry Supervisor D. R. Robinson, Operations QA Supervisor
- J. V. Sayer, Radiological Manager D. C. Shrader, Assistant to Operations Supervisor G. E. Smith, QA Manager
- G. R. Smith, Licensing Supervisor J. R. Warren, Senior Chemistry and Health Physics Specialist
- V. L. Wolstenholm, Division Manager, QA Others
- E. A. Plettner, NRC Resident Inspector
- Denotes those present during the exit interview on April 29, 1988.
2.
NRC Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit interview on April 29, 1988.
These observations are not violations, deviations, unresolved items, or open items.
These observations were identified for licensee consideration for program improvement, but the observations have no specific regulatory requirement.
The licensee stated that the observations would be reviewed.
a.
QA Audit Program - The licensee does not perform a separate audit of the radioactive waste effluent program (RWEP) or the offsite dose assessment manual (0 DAM).
(See paragraph 5.)
b.
Technical Specification (TS) Surveillance Tests - The licensee had not established specific individual surveillance test procedures to perform and track completion of all Radiological Effluent Technical Specifications (RETS) requirements.
(See paragraph 7.)
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Semiannual Effluent Release Reports - The licensee had not addressed in every semiannual effluent release report the topics of unplanned releases, changes to the process control program, and changes to the ODAM.
(De paragraph 7.)
3.
Organization and Management Controls (83522/83722)
The NRC inspector reviewed the licensee's organization, staffing, identification and correction of program weaknesses, audits and appraisals, communication to employees, and documentation and
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implementation of the RWEP to determine adherence to commitments in
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Section XIII-2 in the Updated Safety Analysis Report (USAR) and the requirements in Section 6.1 in the TS.
The NRC inspector verified that the organizational structures of the CNS radwaste operations section and chemistry / radiochemistry section (C/RS)
were as defined in the USAR and TS.
The CNS management control procedures and position descriptions were reviewed for the assignment of responsibilities for the management and implementation of the CNS RWEP.
The NRC inspector verified that the administrative control responsibilities specified in CNS procedures were being implemented.
Selected procedures and records listed in Attachment 1 to this report were reviewed.
The NRC inspector reviewed the staffing of the radwaste operations section and the C/RS and determined that toth sections were fully staffed.
Since the previous NRC radwaste inspection in December 1986, the licensee's
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radwaste operations section and the C/RS had experienced no personnel turnover.
A review of the operations shift crew assignments indicated that four new station operators had been added to the shift crews since December 1986.
No violations or deviations were identified.
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4.
Training and Qualifications (83523/83723)
The NRC inspector revicwed the licensee's training and qualification
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program for C/RS personnel and nonlicensed radwaste station operators responsible for the RWEP including:
education and experience, adequacy and quality of training, employee knowledge, qualification requirements,
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new employees, Institute of Nuclear Power Operations accreditation, and audits and appraisals to determine adherence to commitments in Section XIII-3 in the USAR and the requirements in Section 6.1.4 in the
TS.
l The NRC inspector reviewed the qualifications of present C/RS staff and selected nonlicensed station operators responsible for the implementation
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of the RWEP and verified that they met the required qualifications
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l specified in the USAR and TS.
It was determined that the licensee nad an adequately qualified staff.
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The NRC inspector reviewed the licensee's training program for C/RS personnel and nonlicensed radwaste operators, including a review of course
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descriptions, personnel training records, and qualification cards.
The NRC inspector found that the licensee's training program was being implemented in accordance with CNS procedures.
The NRC inspector reviewed individual staff training records and qualification cards for selected C/RS personnel and nonlicensed radwaste operators responsible for performing RWEP activities.
The NRC inspector verified that all C/RS technicians and nonlicensed station operators responsible for performing RWEP activities and completed the required training on the RETS and radwaste systems to perform liquid and gaseous effluent releases.
No violations or deviations were identified.
5.
Liquids and Liquid Wastes (84523/84723]
The NRC inspector reviewed the licensee's liquid radioactive waste effluent program including:
liquid waste system construction and installation; liquid leakage, overflow, and spillage; liquid waste sampling; liquid process and effluent monitors; procedures for liquid waste and effluent systems; reactor coolant and secondary water quality; and audits and appraisals to determine adherence to commitments in Sections VII-12, IX-2, IX-6, XIII-6, and XIII-9 in the USAR and the requirements in Sections 3/4.2, 3/4.21, 6.2, 6.3, 6.7, and 6.8 in the TS and the 00AM.
The NRC inspector reviewed the licensee's implementation of the RETS and ODAM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, RWEP operating procedures, offsite dose results from liquid effluents, and functional checks and calibrations of equipment associated with the radioactive liquid waste processing system.
Selected documents and records listed in Attachment 1 to this report were reviewed.
The NRC inspector reviewed current approved revisions of CNS procedures governing the release of liquid radioactive waste.
These liquid effluent release procedures provide for the following:
sampling of radioactive waste; chemical and radionuclide analyses prior to release; calculation of effluent release rates, effluent radiation monitor setpoints, projected offsite radionuclide concentrations, and offsite doses prior to release; recording effluent dilution parameters during releases; and verifying discharge flow rates and effluent volume discharged.
The NRC inspector reviewed a representative number of liquid release permits for the period January 1987 through March 1988.
It was determined that processing, sampling and analysis, and approval and performance of the releases were conducted in accordance with CNS procedures.
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of radioactive nuclides released in the liquid effluents were within the limits specified in the RETS.
Offsite doses had been calculated according to the ODAM and were within the TS limits.
Liquid effluent radiation monitor setpoints were being calculated in accordance with the ODAM.
The NRC inspector determined that no design i
changes had been made to the liquid waste systems since the previous NRC l
inspection conducted in December 1986.
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The NRC inspector reviewed procedures and selected reactor water chemistry l
records for the period January 1987 through March 1988.
The records reviewed indicated that all required sampling and analyses were performed
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at the frequencies required by the TS.
The NRC inspector reviewed source checks, channel function tests, calibrations, and setpoint procedures and records for radioactive waste liquid effluent monitors which showed that the frequency of channel functional checks and calibrations met TS requirements.
The NRC inspector verified that the monitor calibrations were being performed using radioactive standards traceable to the National Bureau of Standards and were of various activity levels to cover the entire range of each monitor.
The calibrations and monitor setpoint determinations were verified to have been performed according to approved procedures.
The NRC inspector visually inspected the location and operation of the effluent radiation monitors and determined that the radwaste effluent radwaste monitors were operable at the time of the inspection and met TS requirements.
The service water effluent monitor and the radwaste ventilation monitor were temporarily out-of-service while maintenance was being performed.
The NRC inspector reviewed surveillance test procedures and records to detertaine compliance with the channel check and calibration requirements for the liquid radwaste effluent line flow rate monitors.
It was noted that the liquid radwaste effluent flow rate monitors, RW-FIT-485 and RW CIT-442, were last calibrated on July 14, 1986, in accordance with Surveillance Procedure 6.3.7.3, "Liquid Radwaste Effluent Flow Monitor Calibration," Revision 0, June 26, 1986.
The calibration frequency requirement for these flow monitors is once per cycle or by TS definition at least once per 18 months.
This item was discussed with the licensee during the inspection and at the exit interview on April 29, 1988.
The flow monitors were calibrated satisfactorily by the licensee on April 29, 1988, within the 25 percent time allowance defined for surveillance tests in the TS.
The NRC inspector reviewed the CNS QA organization, selected QA audit and surveillance procedures, audit and surveillante schedules for 1987 and 1988, and the qualifications of auditors.
Selected QA surveillance and audit reports concerning QA activities performed during 1987 in the areas of chemistry and liquid radwaste processing were reviewed for scope to
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ensure thoroughness of program evaluation and timely followup of identified findings.
The NRC inspector found the audit plans, checklists, and surveillances to be comprehensive.
The NRC inspector made the following observations which would provide program improvements in the radwaste effluent program audit process:
a.
the radwaste effluent program is included as part of the chemistry / radiochemistry audit and could be better performed as a separate audit, b.
the licensee's audit team for conducting radwaste effluent program audits does not have an auditor who has received specific training in the station radwaste management systems or release procedures, and c.
the licensee has not developed a specific audit of the ODAM.
These observations were discussed with the licensee at the exit interview on April 29, 1988, and the licensee agreed to evaluate the observations for program improvement.
The NRC inspector determined that the licensee was using a contractor laboratory to perform the 55Fe analysis on radioactive liquid waste effluent required by TS.
The licensee was also using a contractor to perform in place filter testing and laboratory charcoal adsorber analyses on the station ventilation systems as required by TS.
The licensee had performed QA audits on both of these contractors and had placed them on the CNS approved supplier list.
The NRC inspector reviewed the audits performed by the licensee on the two contractors and found the audits to be adequate.
No violations or deviations were identified.
6.
Gaseous Waste System (84524/84724)
The NRC inspector reviewed the licensee's gaseous radioactive waste effluent program including:
gaseous waste system construction and installation, gaseous waste sampling, gaseous process and effluent monitors, procedures for gaseous waste and effluent systems, air cleaning systems, and audits and appraisals to determine adherence to commitments in Sections VII-12, IX-4, IX-5, XIII-6, and XIII-9 in the USAR and the requirements in Sections 3/4.2, 3/4.7, 3/4.12, 3/4.21, 6.2, 6.3, 6.7, and 6.8 in the TS and ODAM.
TheNRCinspectorreviewedthelicensee'simplementationoftheRITSand ODAM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, RWEP operating procedures, offsite dose results from gaseous effluents, and functional checks and calibrations of equipment associated with the radioactive gaseous waste processing system.
Selected documents and records listed in Attachment 1 to this repo*t were reviewed.
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The NRC inspector reviewed current approved revisions of CNS procedures governing the release of gaseous radioactive waste.
These gaseous effluent release procedures provide for:
the sampling of gaseous radioactive waste, calculation of projected offsite radionuclide concentrations and doses, calculations and verification of gaseous effluent radiation monitor setpoints, and verification of discharge flow rates and effluent volume discharged.
Selected documents and records listed in Attachment 1 to this report were reviewed.
The NRC inspector reviewed selected analyses of samples taken from the elevated release point, reactor building ventilation, augmented radwaste building ventilation, and turbine building ventilation continuous release paths for the period January 1987 through March 1988.
It was determined that the continuous gaseous waste releases were being performed according to procedure and the quantities of gaseous radioactive nuclides released were within the limits specified in the RETS.
Offsite doses had been calculated according to the 00AM, updated biweekly, and were within the TS limits.
The NRC inspector reviewed daily readings taken from the noble gas monitor and recorded on the appropriate data form and determined that the TS requirement was being met.
The NRC inspector reviewed selected operations daily surveillance log sheets for the period January 1987 through March 1988 and verified continuous monitoring of the hydrogen concentration in the augmented offgas treatment system downstream of the recombiners.
The NRC inspector determined that no design changes had been made to the gaseous radwaste management system since the previous NRC inspection in December 1986.
The NRC inspector reviewed source checks, channel functional tests, calibrations, and setpoint procedures and records for gaseous radioactive waste effluent monitors and verified that the frequency of the various checks and calibrations met TS requirements.
The monitor calibrations and setpoint determinations were verified to have been performed according to approved procedures.
The NRC inspector reviewed the licensee's procedures and surveillance tests for maintenance and testing of air cleaning systems which contain high efficiency particulate air (HEPA) filters and activated charcoal adsorbers.
The NRC inspector verified that the licensee's procedures and surveillance tests provided far tF.; required periodic functional checking of ventilation system components, evaluation of HEPA and activated charcoal adsorbers, tracking of system operating hours, and replacement and in place testing of filter systems.
The licensee's surveillance test results for the period January 1987 through March 1988 were reviewed and verified to be within TS limits.
Selected documents and surveillance tests listed in Attachment 1 to this report were reviewed.
No violations or deviations were identified.
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i 7.
Reports of Radioactive Effluents The NRC inspector reviewed the licensee's records and reports concerning radwaste systems and effluent releases for compliance with the requirements of 10 CFR Part 50.36(a)(2) and Section 6.5.1.F in the TS.
The NRC inspector reviewed the semiannual effluent release reports for the periods July 1 through December 31, 1986, January 1 through June 30, 1987, and July 1 through December 31, 1987.
These reports were written in the format described in NRC Regulatory Guide 1.21 and contained the information required by TS.
However, the NRC inspector observed that in two of the semiannual effluent release reports reviewed the topics of unplanned releases and changes to the process control program and ODAM were not addressed since no unplanned releases occurred and no changes had been made to the referenced documents.
This observation was discussed with the licensee at the exit interview on April 29, 1988, and the licensee agreed to reference each of these specific TS requirements in future semiannual effluent release reports.
The NRC inspector reviewed the implementation of RETS for the period January through December 1987.
It was determined that all required data were available; however, it was observed that not all RETS requirements
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were being addressed in specific individual surveillance procedures which would perform and track completion of TS requirements at specified frequencies and provide a concise method for reporting TS surveillance data.
This observation was discussed with the licensee during the inspection and at the exit interview on April 29, 1988, and the licensee stated that they would evaluate the NRC inspector's observation for program improvement.
No violations or deviations were identified.
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8.
Exit Interview The NRC inspector met with the NRC resident inspector and the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on April 29, 1988.
The NRC inspector summarized the scope and findings of the inspection and discussed the NRC inspector's observations.
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licensee represantatives stated at the exit interview that they would evaluate the NRC inspector's observations and concerns and take necessary
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corrective action to implement program improvements.
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ATTACHMENT _1 Cooper Nuclear Station NRC Inspection Report 50-298/88 12 Documents Reviewed Title Revision Date 1.
Administrative Procedures 0.2, Station Organization and Responsibility
04/14/88 0.17, Selection and Ti mining of Station Personnel
04/07/88 0.26, Surveillance Program
10/15/87 2.
System Operating Procedures 2.2.62, Radioactive Waste System - Gaseous
02/26/87 2.2.73, Standby Gas Treatment System
02/25/83 3.
Radwaste Procedure 2.5.2.3, Radwaste High Conductivity Liquid Waste
03/19/87 Floor Drain Sample Task Fluid Transfer 4.
Surveillance Procedures 6.2.4.1, Daily Surveillance Log (Technical
04/14/88 Specifications)
6.2.6.1, Off Gas System Auto Isolation Functional
12/03/87 Test 6.2.6.2, Augmented Off Gas Hydrogen Monitors
01/21/88 Calibration 6.2.6.4, Off Gas flow Monitor Calibration
12/23/87 6.2.6.7,SteamJetAirEjectorFlowMonitor
10/08/87 Calibration 6.2.6.8, Augmented Off Gas Hydrogen Monitors
12/23/87 Functional Test 6.3.7.2, Off Gas Radiation Monitor Calibration and
04/07/88 Functional / Functional Test
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6.3.7.3, Liquid Radwaste Effluent Flow Monitor
06/26/86
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Calibration 6.3.7.4, SW and REC Radiation Monitor Calibration
01/21/88 Check and Instrument Channel /Instrement Channel Test 6.3.7.5, Reactor Building Ventilation Radiation
03/12/87 Monitor Calibration and Functional /
Functional Test 6.3.7.6, Liquid Radwaste Effluent Flow Monitor
06/26/86 Functional Test 6.3.7.7, Liquid Radwaste Effluent System Calitration
12/17/87 and Functional / Functional and Logic Tests 6.3.7.8, ERP Radiation Monitor (Kaman) Known Source
03/12/87 Calibration Check / Functional Test 5.3.17.4, Control Room Emergency Fan HEPA Filter Leak
02/26/87 Test 6.3.17.5, Control Room Emergency Fan Charcoal Leak,
02/15/84 Charcoal Sampling, and Fan Capacity Testing 6.3.17.6, HVAC Radwaste Building HEPA Filters Leak
02/10/86
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Test 6.3.17.7, HVAC Reactor Building HEPA Filters Leak
06/26/86 Test 6.3.17.8, HVAC Augmented Radwaste Building HEPA
06/26/86 Filters Leak Test 6.3.17.10, EOF /TSC Emergency Air Filter In-Place HEPA
12/26/85 Leak Test 6.3.17.11, EOF /TSC Emergency Air Filter In-Place
09/05/85 Charcoal Leak Test and Laboratory Analysis 6.3.19.1, SGT Operability Test /0ff-Gas Flow Monitor
03/03/88 Functional Test 6.3.19.2, SGT Filter Differential Pressure, Heater
09/17/87
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Output, and Fan Motor Running Current Test
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6.3.19.3.1, SGT Train A HEPA Filter Leak and Housing
03/03/88 Door Seal Leak Test 6.3.19.3.2, SGT Train B HEPA Filter Leak and Housing
03/03/88
Door Seal Leak Test
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6.3.19.4, SGT Charcoal Filter Leak and fan Capacity
09/17/87 Test 6.3.19.5, SGT Charcoal Filter Carben Analysis -
05/01/86
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Menthyl Iodide 6.4.6.1, Reactor Building Air Sampling System
03/12/87 f
(Kaman) Functional Test and Known Source Calibration Check 6.4.6.3, Control Room Vent Monitors Calibration and
05/21/87 Functional / Functional Logic Tests 6.4.6.4, Turbine Building Air Sampling System (Kaman)
03/12/87 Functional Test and Known Source Calibration Check 6.4.6.5, Radwaste Building Air Sampling System (Kaman)
03/12/87 Functional Test and Known Source Calibration Check
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6.4.6.9, Turbine Building Air Sampling System (Kaman)
04/07/88 r
Electronic Calibration Test 6.4.6.10, EPR Radiation Monitor System (Kaman).
03/10/88 Electronic Calibration Test 6.4.6.11, Radwaste Building Air Sampling System (Kaman)
03/10/d8 Electronic Calibration Test 6.4.6.12, Reactor Building Air Sampling System (Kaman)
03/10/88
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Electronic Calibration Test 6.4.6.13, Turbine Building Ventilation Flow Monitor
05/15/86 Calibration Test
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6.4.6.14, Reactor Building Ventilation Flow Monitor
10/09/86 Calibration Test 6.4.6.15, Radwaste Building Ventilation Flow Monitor
02/20/87 Calibration Test 6.4.6.16, Steam Jet Air Ejector Flow Monitor
09/04/86 Functional Test
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8.2.1', bhemistry 'Analy.c,4s and n;tclument Calibration
07p2/86 Schedule l
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8.4, Routire Sampling Procedure and Liquid / Gas Sample
lb Q1/87
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8.6.:1, Air Ejector 0ff Gas ~ Radiation Monitor
07/10/86
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02/08/88 8.6.2,lERPandVent-MonitorCibrations j ,. 8.6.3,. Li. quid Process Radiati6n' Monitors SW and REC /
06/30/86 -) i - . 8.6.4,RadwasteLiquidProcessRadiat.jon, Monitor 11-07/17/87 ,
l 8.8.L14, Radiochemical Analysis Iodnas .
11/13/86 t < if ls ' 8.8.1.17, Radiochemical -Noble Gas Sa:.d? 14 l l;
.08/27/87 3 3 7
. 8.8.1.25;: bdiochemical' stronti'c M Yttrich, Anal [si/s
10/02/86 . f - (i 8.8.1'.31, Radicchemical Analysis of Tritw.-
'06/26/86 y 8.8.4, Off Gas Grab Samples Isotopic Analych
01/29/87, ' . / 8.8.5, Determination of Off-Gas Flow Rate
01/15/87
8.8.7, Liquid Waste Discharge Preparation and Analysis
03/12/87 s 'i 8.8.8,. Particulate, Iodine, and Noble Gcs Sample
04M5/87
Collection for Effluent Monitm.
' i .l 8.8.11, Liquid Radioactive Waste Discharge
01/08/87 !! ' Authorization / 8.11.1, Effects Program
09/38/86 f '
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Cher.istry Data Forms S.2.12.0.1, 8.4.1.1.1, 8.4.5.1.6-C, 8.4.5.3.4-A, 8.4.5.3.4-B, 8.4.5.3.5-B, 8:4.7.2.2, 8.4.8.2.2, 8.4.11.1.2-A, 8.4.11.2.2-A, 8.4.11.9.2, 8.4.12.2.5-A, 8.4.12.2.5-B, 8.4.12.3.2-A, 8.5.5.3.5, 8.5.8.2.5, 8.5.11.10-A, 8.5.12.1.5 % ,, 7., Quality Assurance (QA) Audits , "s (.QA Audit Report 87-12, QAP-900-Chemistry, dated January 6, 1988 ' dj QA Audit Report 87-16, QAP-900-Environmental, dated December 11, 1987 I ', 2/ OfpVendor Audit Report V85-38-01, EAL Corporation, dated November 20, 1985 '> ',) ~,. < QA Vendor CASE Audit Report, Nuclear Containment Systems, dated Oeoember 5, 1986 ' 8.
C_o_oper Nuclear Station Semiannual Effluent Release Reports July 1 through December 31, 1986 January 1 through June 30, 1987 July 1 th ough December 31, 1987 d i [ i }}