IR 05000298/1991003
| ML20217B593 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/27/1991 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217B557 | List: |
| References | |
| 50-298-91-03, 50-298-91-3, NUDOCS 9103120159 | |
| Download: ML20217B593 (14) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-298/91-03 Operating License:
OPR-46 Docket:
50-298 Licensee: Nebraska Public Power District (NPPD)
P.O. Box 499 Columbus, Nebraska 68602-0499 Facility Name:
Cooper Nuclear Station (CNS)
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Inspection At:
CNS Site, Brownville, Nemaha County, Nebraska Inspection Conducted:
February 4-8, 1991 Inspector:
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s.E Ae 4 /.:7 /f /
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J4 8. Nicholas, Senior Radiation Spec 1alist Date Radiological Protection and Emergency Preparedness Section Approved:
,/ddlMA6 6LK )
L/2M!9/
Blaine $ Pray, Chief, Radiulogical Date Protection and Emergen Preparedness Section Inspection Summary Insoection Conducted February 4-8, 1991 (Recort 50-298/91-03)
Areas Insoected:
Routine, announced inspection of the licensee's liquid and gaseous radioactive effluent ~ systems.
Results: The inspector determined that the licensee was implementing the radioactive waste effluent program (RWEP) in accordance with the Radiological Effluent Technical Specifications (RETS) and Offsite Dose Assessment Manual (ODAM). The licensee had performed 300 radioactive liquid batch releases during 1989 and 1990.
The quantities of radionuclides released-in the radioactive effluents were within the limits specified in the RETS.
Offsite doses had been calculated using methods described and specified in the ODAM and were within Technical Specification (TS) limits. The licensee had no unplanned radiological releases during 1989 and 1990.
The licensee had not made any equipment or design changes in the radioactive effluent management systems during 1989 and 1990.
9103120159 910301 PDR ADOCK 0S000298 o
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The licensee's ventilation systems had been tested in accordance with TS requirements. Quality Assurance (QA) surveillances and audits had been performea as required and were technically comprenensive.
The licensee had made enanges to their ODAM and documented these changes in the appropriate Semiannual Radiological Effluent Release Reports per TS requirements. No-licensee Event Reports (LERs) had been written in 1989 and 1990 involving radioactive effluent release activities.
The licensee had suomitted their Semiannual Radiological Effluent Release Reports for 1989 and the first half of 1990 as per TS requirements.
Within the areas inspected, no violations or ceviations were identified.
The licensee haa adequately addressed all previously icentifiec violations, deviations, unresolved items, open items, and inspect 0r observations in the area of racioactive effluents.
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Persons Contacted
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- J..M. Meacham, Division Manager, Nuclear Operations R. L. Beilke, Radiological Support Supervisor
- L.- E. Bray', Regulatory. Compliance Specialist
- M.-A;-Dean, Nuclear Licensing and Safety Supervisor
- J. W. Dutton, Training Manager
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- K. L. Fike, Chemist-
- R. L. Gardner, Senior. Operations Manager
- R. J. ' Mcdonald, Chemistry Supervi ser J. L. Peaslee, Surveillance Coordinator C.LH. Putmam, Jr., Senior QA Specialist
- J. V. Sayer, Radiological Manager
- G. E. Smith, QA Manager D. L. Snyder, Chemistry Training Instructor
'J. R. Warren, Senior Chemistry and Health Physics Specialist
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' M. ' C_. Wright, Lead Chemi stry Tecnnician NRC
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'*W. R. Bennett, Senior Resident Inspector, CNS'
G. A. Pick, Resident Inspector, CNS
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- Indicates those present at the exit meeting on February 8, 1991.
2.
-Followuo on Previously~ Identified Inspection Findings (92702):
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(Closed)-Violation (298/9030-01): Postaccident Sampling System (PASS)
Training --This violation was identified in NRC Inspection
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Report 50-298/90-30 and involved the licensee not conducting PASS operator requalification~ training for all chemistry technicians on a 6-month-frequency. The li_censee.had conducted PASS operator requalification training for all chemistry staff during October _and November 1990 bringing
.their PASS operator requalification training requirements current.
The
' inspector reviewed the licensee's corrective actions in response to the
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violation including.the changes to Administrative Procedure 0.17,
" Selection and Training of. Station Personnel," Revision 12, November 19, 1990, and the implementation of the licensee's requalification training -
l, tracking. system.
The licensee's corrective actions appeared to resolve the violation.
3.
Organization and Management Controls (84750)
The inspector reviewed the licensee's organization, staffing, and staff functional' assignments related to the liquid and gaseous radioactive effluent programs to determine agreement with commitments in Section XIII l -
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-4-of the Updated Safety Analysis Report (USAR) and compliance with the requirements in Section 6.1 of the TS.
The inspector verified that the organizational structure of the CNS chemistry section responsible for the RWEP was as defined in the USAR and TS. The CNS staff assignments and management control procedures were reviewed for the assignment of responsibilities for the management and implementation of the CNS RWEP. The organizational structure and staffing of the chemistry section for managing and performing the RWEP appeared to be adequate to meet the requirements for the routine performance of the liquid and gaseous radioactive effluent activities.
The inspector verified that the administrative control responsibilities specified in the CNS procedures were being implemented.. Selected procedures listed in the attachment to this repc-t were reviewed.
The inspector reviewed the staffing of the enemistry section and determined that it was fully staffed and that no changes had been made since the previous NRC RWEP inspection in June 1989.
No violations or deviations were identified.
Trainino and Qualifications (83523)
The insoector reviewed the licensee's training and qualification program for chemistry section personnel responsible for conducting the RWEP to determine agreement with commitments in Section XIII of the USAR and compliance with the requirements in Section 6.1.4 of the TS.
The inspector reviewed the qualifications of the present chemistry section staff and verified that they all met the recuired qualifications specified in the USAR and TS. -It was determined that the licensee had an adequately qualified staff.
The inspector reviewed individual staff training records for selected chemistry section personnel who perform RWEP activities.
It was verified that all chemistry technicians responsible for RWEP activities had completed the required training on the RETS and radicactive effluent systems to perform liquid and gaseous radioactive effluent releases.
No violations or deviations were identified.
5.
Liquid Radioactive Effluents (84750; l
The inspector reviewed the licensee's liquid radioactive effluent program l
including:
liquid effluent sampling, liquid effluent radiation monitors,
- procedures for liquid radioactive waste systems, and reactor water quality to determine agreement with commitments in Sections VII-12, IX-2, and IX-6 of the USAR and compliance with the requirements in Sections 3/4.2, 3/4.21, 6.3, 6.7, and 6.8 of the TS and the 00AM.
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The inspector reviewed the licensee's implementation of the RETS and 00AM to ensure agreement with sampling and analysis requirements, analysis sensitivities, reporting limits, analytical results, surveillance tests, RWEP cperating procedures, offsite dose results from liquid effluents, and functional checks and calibrations of equipment and radiation monitors associated with the radioactive liquid waste processing system.
Selected documents and records listed in the attachment to this report were reviewed.
The inspector reviewed current approved revisions of CNS procecures governing the release of liquid radioactive waste.
These radioactive liquid effluent release procecures provided for the following:
recirculation and sampling of radioactive liquid waste; chemicai and radionuclide analyses prior to release; calculation of effluent release rates, effluent radiation monitor setpoints, projected of f site radionuclide concentrations, and offsite doses prior to release; recorcing effluent dilution parameters during releases; and verifying disenarge flow rates and effluent volume discharged.
The insoector reviewed a representative numoer of licuid release permits for the period June 1989 througn Decemoer 1990.
It was determined tnat the processing, sampling, and analysis of liquic radioactive waste effluent and the approval and performance of liquid radioactive waste discharges were conducted in accordance with CNS procedures.
Quantities of radioactive nuclides released in the licuid effluents were within the limits specified in the RETS. Offsite doses nac been calculatec according to the ODAM and were within the TS limits.
The inspector reviewed 1990 monthly dose results and verified that the calculated doses were within tne limits established in the RETS and that appropriate supervision had reviewed the calculated dose results to determine TS compliance.
The inspector reviewed source checks, channel functional tests, channel calibrations, and alarm / trip setcoint surveillance procedures and records for radioactive liquid effluent monitors and verified that the frequency of the surveillance tests met TS requirements. The inspector verified that the licensee had performed the radiation monitor calibrations using radioactive standards in the same media and configuration as the actual liquid samples being measured in the liquid effluent streams. The radioactive standards used were traceable to the National Institute of Standards and Technology. The radiation monitor calibrations and setpoint determinations were verified to have been performed according to approved procedures and the 00AM.
The inspector reviewed selected reactor water chemistry records for the period June 1989 through December 1990. The records reviewed indicated that all required sampling and analyses were performed at the frequencies required by the TS, and the analytical results did not indicate excessive radioactivity which would influence the racioactivity discharged in the liquid radioactive effluents.
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-6-The inspector determined that no design changes had been mace to the liquid racwaste systems since the previous NRC inspection of the RWEP conducted in June 1989.
No violations or deviations were identified.
6.
Gaseous Radioactive Effluents (84750)
The inspector reviewed the licensee's gaseous radioactive effluent program including:
gaseous effluent sampling and analyses, gaseous process and ef fluent monitors, procedures for caseous ef fluent systems, and air cleaning systems to determine agreement with commitments in Sections VII-12, IX-4, and IX-5 of the USAR and compliance with the cequirements in Sections 3/4.2, 3/4.7, 3/4.12, 3/4.21, 6.3, 6.7, and 6.8 of the TS and the ODAM.
The inspector-reviewed the licensee's implementation of the RETS and ODAM to ensure agreement with sampling and analysis reouirements, analysis sansitivities, reporting limits, ana'ytical results, surveillance tests, RWEP operating procedures, offsite dose results from gaseous effluents, and functional checks and calibrations of eouipment anc radiation monitors associated with the radioactive gaseous waste processing systems.
Selected documents and records listed in the attachment to this report were reviewed.
The inspector reviewed approvec revisions of CNS procecures governing the release of gaseous radioactiva effluents.
These gaseous effluent release procecures provided for the samoling and analyses of gaseous radioactive effluents, calculation of offsite radionuclide concentrations and doses, calculation and verification of gaseous effluent radiation monitor setpoints, and verification of effluent flow rates and volume discharged.
The 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 June 1989 through December 1990.
It was determined that the continuous gaseous effluent 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 RETS limits. The inspector reviewed selected daily readings taken from the noble gas monitor and recorded on the Operations-Daily Surveillance Log and determined that the TS requirement was met.
Selected Operations-Daily Surveillance Logs for the period June 1989 through December 1990 were reviewed, and the continuous monitoring of the hydrogen concentration in the augmented offgas treatment system was verified.
It was determined that the licensee had made no design changes to the gaseous radwaste management systems since the previous NRC inspection of the RWEP conducted in June 1989.
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The inspector. reviewed source checks, channel functional tests, channel calibrations, and alarm / trip setpoint surveillance procecures and records for radioactive gaseous effluent radiation monitors and verified that the frequency of the various surveillance tests met TS recuirements. The inspector verified that the licensee had performed the initial radiation monitor calibrations using gaseous radioactive stancards in the same configuration as the actual gaseous samples being measured in the gaseous effluent streams.
The radioactive standarcs used were traceable to the National Institute of Standards and Tecnnology.
The radiation monitor
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calibrations and setpoint determinations were verified to have been
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performed according to approvec procedures anc the ODAM,
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The inspector reviewed the licensee's procecures, surveillance tests, and selected records and test results for maintenance anc testing of air cleaning systems which contain high ef ficiency particulate air (HEPA)
filters and activated charcoal adsoreers.
The inspector verified that the licensee's procedures and surveillance tests provided for the required periodic functional checking of ventilation comoonents, evaluation of HEPA and activated charcoal adsorcers, and replacement anc in-place filter testing of the filter systems.
Records anc test results for the period July 1989 through December 1990 for the main control room emergency ventilction and the stanocy gas treatment systems were reviewed.
The in place filter testing and activated charcoal laboratory tests had been performed in accordance with accroved procedures by a contract laboratory, and all test results were-verified to be within TS limits.
In response to a orevious inspector observation, the licensee nad acded steps to an ex...ing procedure to monitor and document the operating hours of the various ventilation systems requiring TS testing.
No violations or deviations were identified.
7.
Quality Assurance Audit procram (84750)
The inspector reviewed the licensee's QA audit ant surveillance programs fcr the RWEP to determine agreement with commitments in Section XIII of the USAR and compliance with the requirements in Section 6.2 of the TS, QA surveillance and audit plans and checklists for RWEP activities, selectedl}A procedures, and QA audit schedules for 1990 and 1991 were reviewed. QA audit reports concerning QA activities performed during 1989 and 1990 in the areas of radioactive liquid and gaseous effluents were reviewed for scope to ensure thoroughness of program evaluation and timely followup of identified findings.
The inspector found the licensee's QA audit plans and checklists comprehensive and satisfactory to evaluate the licensee's performance in implementing the RETS and ODAM requirements. QA audits reviewed are listed in the attachment to this report.
The licensee was using a contractor laboratory to perform the iron-55, strontium-89, and strontium-90 analyses on the racioactive effluent quarterly composite samples as required by TS. The licensee was also using a contractor to perform in place filter testing and laboratory
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-8-chat,v..I adsorber analyses on the plant ventilation systems as required by TS.
The licensee had performed QA audits on botn of these contractors and had placed them on the CNS approved supplier list.
The inspector reviewed the most recent audits performed on the two contractors and found the audits to be adequate.
No violations or deviations were identified.
8.
Licensee Event Reoorts (84750)
The inspector determined that the licensee had not written any LERs that involved radioactive effluent release activities since the previous NRC inspection of the RWEP in June 1989.
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No violations or deviations were identified.
9.
Reports of Radioactive Effluents (84750)
The inspector reviewed the licensee's reports concerning radicactive waste systems and effluent releases to determine compliance with the requirements of 10 CFR Part 50.36(a)(2) ano Section 6.5.1 of the TS.
The inspector reviewed the licensee's Semiannual Radiological Effluent Release Reports for the periods January 1 througn June 30,1989, July 1 through December 31, 1989, and January 1 througn June 30, 1990.
These reports were written in the format described in NRC Regulatory Guide 1.21 and contained the information required by TS.
During the period January.1,1989, through June 30, 1990, the licensee had performed 215 liquid batch releases, The licensee reported no unplanneo radioactive liquid or gasecus releases during the time period reviewed.
No cnanges were made to the Process Control Program during the time period reviewed.
Changes had been made to the 00AM and were approved on January 27, 1989, and on August 10, 1989, by the Station Operations Review Committee.
The inspector reviewed the changes to the ODAM and found them satisfactory and well documented in the respective Semiannual Radiological Effluent Release Reports as required by TS.
No major changes had been made to the liquid and gaseous radwaste systems durirg the time period reviewed.
Effluent monitoring instrumentation had not been out of service in excess of TS requirements.
No violations or deviations were identified.
10.
Exit Meeting (30703)
The inspector met with the NRC senior resident inspector and the licensee i
representatives identified in paragraph 1 of this report at the conclusion of the inspection on February 8,1991.
The inspector summarized the scope and findings of the inspection.
The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectcr during the inspection.
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ATTACHMENT COOPER NUCLEAR STATION NRC Inspection Report:
50-298/91-03 Documents Reviewed Title Revision Date 1.
Administrative Procedures 0.2, Station Organization ano Responsibility
04/25/90 0.17, Selection and Training of Station
11/29/90
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Personnel O.26, Surveillance Program
01/10/91
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System Operatino Procedures 2.2.62, Radioactive Waste System - Gaseous
10/06/88 2.2.73, Standby Gas Treatment System
'22 04/03/90 3.
Radwaste Procedures 2.5.1.1, Radwaste Low Conductivity Liquid
06/21/89 Condensate Backwash Tank Fluid Transfer 2.5.1.2, Radwaste Low Conductivity Liquid Waste
03/29/90 Condensate Phase-Separator Fluid Transfer 2.5.1.3, Radwaste Low Conductivity Liquid Waste
04/27/89 Spent Resin Tank Fluid Transfer 2.5.1.4, Radwaste Low Conductivity Liquid Waste
05/24/90 Collector Processing 2.5.1.5, Raowaste Low Conductivity Liquid Waste
03/08/90 Surge Tank Procersing 2.5.1.6, Radwaste Low Conductivity Liquid Waste
05/17/88 Sample Tank Fivid Transfer 2.5.1.7, RWCU Phase Separator Tank Transfer
05/17/90
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2.5.2.1, Radwaste High Conductivity Liquid Waste 10 03/29/90 l
and Waste Sludge Tank Fluid Transfer l
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2.5.2.2, Radwaste High Conductivity Liquid Waste 10 05/24/90 Floor Orain Processing 2.5.2.3, Radwaste High' Conductivity Liquid Waste 32 04/12/90 Floor Drain Sample Tank Fluid Transfer 2.5.2.4, Chemical Waste Tank Transfer
09/11/87-4.
Surveillance Procedures 6.2.4.1, Daily Surveillance Log (Technical
07/13/90 Specifications)
6.2.6.1, Off Gas System Auto Isolation
06/01/89 l-Functional Test l
6.2.6.2, Augmented Off Gas Hydrogen Monitors
09/13/90 Calibration 6.2.6.4, Off Gas Flow Monitor Calibration
10/04/90 l
6.2.6.7, Steam Jet Air Ejector Flow Monitor
10/04/90 Calibration l
6.2.6.8, Augmented Off Gas Hydrogen Monitors
11/30/89 i
Functional Test l
l 6.3.7.2, Off Gas Radiation Monitor Sourta Cneck
04/27/90 L
Test
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6.3.7.2.1, Off Gas Radiation Monitor Functional
12/29/88 l
Test l
l 6.3.7.2.2, Off Gas Radiation Monitor Calibration
11/21/90 and Functional Test 6,3.7.2.3, Off Gas Radiation Monitor Linearity
l'./21/90 Test and Efficiency Determination 6.3.7.3, Liquid Radwaste Effluent Flow Monitor
10/04/90 Calibration 6.3.7.4, SW Radiation Monitor Instrument Channel
11/01/90 Test 6.3.7.4.1, SW Radiation Monitor Instrument
01/03/91 Calibration Test 6.3.7.4.2, SW Radiation Monitor Known Source
07/06/89 Calibration
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6.3.7.5, Reactor Building Ventilation Radiation
09/13/90 Source Check 6.3.7.5.1, Reactor Building Ventilation R.2diation 2 09/13/90 Monitor Calibration and Functional Test / Source Check 6.3.7.6, Liquid Radwaste Ef fluent Flow Monitor
05/10/88 Functional Test 6.3.7.7, Liquid Radwaste Ef fluent System
01/25/91 Functional Test 6.3.7.7.1, Liouid Radwaste Effluent System
10/04/90 Calibration Test 6.3.7.7.2, Liquid Radwaste Monitor Known Source
12/21/89 Calibration 6.3.7.8, ERP Kaman Monitor Functional Test
01/17/91 6.3.7.8.2, ERP Kaman Monitor Known Source
04/16/90 Calibration 6.3.17.1, Control Room Ventilation
08/02/90 6.3.17.3, Control Room Emergency Fan Filter
02/15/90 Train Differential Pressure Test 6.3.17.4, Control Room Emergency Fan HEPA Filter 10 04/27/90 Leak Test 6.3.17.5, Control Room Emergency Fan Charcoal
11/29/90 Leak, Charcoal Sampling, and Fan Capacity Testing 6.3.17.8, Augmented Radwaste Building HEPA Filter 4 07/13/89 Leak Test 6.3.19.1, SGT Operability Test /Off Gas Flow
08/02/90 Monitor Functional Test 6.3.19.2, SGT Filter Dif ferential Pressure,
12/14/89
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Heater Output, and Fan Motor Running Current Test l-6.3.19.3.1, SGT Train A HEPA Filter Leak and
03/10/89
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Housing Door Seal Leak Test
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6.3.19.3.2, SGT Train B HEPA Filter Leak and
08/03/89 Housing Door Seal Leak Test 6.3.19.4.1, SGT A Charcoal Filter Leak and
08/10/89 Fan Capacity Test 6.3.19.4.2, SGT B Charcoal Filter Leak and
08/10/89 Fan Capacity Test 6.3.19.5.1, SGT A Charcoal Filter Carbon
06/01/89 Analysis - Methyl Iodide 6.3.19.5.2, SGT B Charcoal Filter Carbon
06/01/89 Analysi: - Methyl Iodide 6.4.6.1.2, Reactor Kaman Mon 1ter Known Source
01/17/91 Calibration 6.4.6.3, Control Room Air Samoling System
04/16/90 Functional and Logic Test 6.4.6.3.1, Control Room Air Sampling System
03/29/90 Known Source Calibration 6.4.6.3.2, Control Room Air Sampling System
04/20/90 Calibratior and Functional Test 6.4.6.4 Turbine Generator Kaman Monitor
01/17/91 Functional Test 6.4.6.4.2, Turbine Gererator Kaman Monitor
04/16/90 Known Source Calibration 6.4.6.5, RW/ARW Kaman Monitor Functional Test
01/17/91 6.4.6.5.2, RW/ARW Kaman Monitor Known Source
04/16/90 Calibration 6.4.6.9, Turbine Building Air Sampling System
04/07/88 Electronic Calibration Test 6.4.6.10, EPR Kaman Monitor System Electronic
09/15/88 Calibration Test 6.4.6.11, Radwaste Building Kaman Air Sampling
03/10/88 Electronic Calibration Test 6.4.6.12, Reactor Building Kaman Air Sampling
03/10/88 Electronic Calibration Test
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6.4.6.13, Turbine Building Ventilation Flow
09/27/90 Monitor Calibration Test 6.4.6.14, Reactor Building Ventilation Flow
12/06/90 Monitor Calibration Test 5.
Chemistry Procedures 8.2.1, Chemistry Analysis and Instrument
04/12/90 Calibration Schedule 8.4, Routine Sampling Procedure and Liquid / Gas
11/09/89 Sample Points 8.8.1.14, Radiochemical Analysis Iedines
11/13/86 8.8.1.17, Radiochemical Noble Gas Sampling
08/27/87 8.8.1.25, Radiochemi 11 Strontium and Yttrium
12/19/88 Analysis 8.8.1.31, Radiochemical Analysis of Tritium
04/23/90 8.8.4, Off Gas Samples Isotopic Analysis
01/29/87 8.8.5, Determination of Off Gas Flow Rate
01/15/87 8.8.7, Liquid Waste Discharge Preparation
11/09/88 and Analysis
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8.8.8, Particulate, Iodine, and Noble Gas
06/P2/89 L
Sample Collection for Effluent Monitors 8.8.11, Liquid Radioactive Waste Discharge
04/28/89 Authorization 8.11.1, Effects Program
10/2]/88 6.
Quality Assurance (QA) and Audits QA Audit Report 89-15, QAP-900 - Chemistry, performed July 18, 1989, through September 22, 1989 QA' Audit Report 89-99, QAP-1200 - Radioactive Waste Treatment and l
Disposal, performed May 9, 1989, through August 3, 1989 l
QA Audit Report 90-18, QAP-90C - Chemistry, performed July 30, 1990,
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through September 5, 1990 l
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QA Audit Report 90-13, QAP-1200 - Radioactive Waste Treatment and Disposal, performed May 24, 1990, through July 20, 1990
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QA Venoor Audit Report, Supplier Reapproval - TMA/Norcal Corporation, dated February 7,1989 QA Vendor Audit Report, Supplier Reapproval - NCS Corporation, dated January 30, 1990 7.
Cooper Nuclear Station Semiannual Effluent Release Reoorts
January 1 through June 30, 1989 July 1 through December 31, 1939 January 1 through June 30, 1990
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