ML20128M730
| ML20128M730 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/11/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128M715 | List: |
| References | |
| 50-298-96-21, NUDOCS 9610160168 | |
| Download: ML20128M730 (36) | |
See also: IR 05000298/1996021
Text
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No..
50-298
License No.-
Report No.:
50-298/96-21
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, Nebraska
Dates:
September 9-13,1996
Inspectors:
J. Blair Nicholas, Ph.D., Senior Radiation Specialist, Plant
Support Branch
Glibert L. Guerra, Radiation Specialist, Plant Support Branch
Thomas H. Andrews, Radiation Specialist, Plant Support Branch
Approved By:
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
Attachment:
Partial List of Persons Contacted
List of Inspection Procedures Used
List of items Opened
List of Acronyms Used
List of Documents Reviewed
9610160168 961011
ADOCK 05000298
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EXECUTIVE SUf' MARY
Cooper Nuclear Station
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NRC inspection Report 50-298/96-21
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These routine, announced inspections focused on the licensee's programs for radiological
waste effluent management, radiological environmental monitoring, and solid radioactive
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waste management and transportation of radioactive materials. Emphasis was placed on
changes to the licensee's programs resulting from the revision of Department of
Transportation and NRC transportation regulations.
Enaineering
A deviation was identified during a review of the Updated Safety Analysis Report
commitments involving the availability of alternate electrical power to the
meteorological monitoring system (Section E2.1).
Plant Support
The liquid and gaseous radioactive waste effluent management programs were
properly implemented (Section R1.1).
Poor sample handling techniques were used while collecting and handling a floor
drain tank sample and the iodine charcoal cartridges from the station's ventilation
systems effluent radiation monitors (Section R1.1).
The safety-related air cleaning ventilation systems were properly maintained and
tested (Section R1.2).
Overall, a good radiological environmental monitoring program was implemented
(Section R1.3).
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Dedicated air sample media holders for each individual air sampler station were not
used (Section R1.3).
A good meteorological monitoring program was implemented (Section R1.4).
The radiochemistry counting f acility was equipped with state-of-the-art analytical
instrumentation to perform the required analyses. The analytical instrumentation
was properly maintained, tested, and calibrated (Section R2.1).
Liquid and r aseous radioactive waste management systems were installed and
operated poperly (Section R2.1).
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All liquid and gaseous effluent radiation monitoring instrumentation were operable
and properly maintained, tested, and calibrated (Section R2.2).
Radiological environmental monitoring sampling equipment was properly maintained
and calibrated (Section R2.3).
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Meteorological tower instrumentation maintenance was poor, which contributed to
a low data recovery rate. An Inspection Followup item was identified regarding the
licensee's rneteorological tower instrument maintenance program (Section R2.4).
Procedures established to imp % ment the liquid and gaseous radioactive waste
effluent management programs provided proper guidance. Excellent Annual
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Operating Report Radioactive Effluents and Annual Radiological Environmental
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Operating Reports for 1994 and 1995, were submitted in a timely manner
(Section R3.1).
Good radiological environmental monitoring implementing procedures with sufficient
detail were in use (Section R3.1).
Programmatic controls and procedures for shipment of radioactive material / waste
were adequate (Section R3.2).
Chemistry personnel and station operators had an excellent understanding of the
radioactive liquid and gaseous waste management procedures, Technical
Specifications, and regulatory requirements (Section R4.1).
The knowledge and performance of the environmental technician responsible for
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implementing the radiological environmental monitoring program activities were
good (Section R4.2).
Training and qualification programs for the chemistry staff and the radwaste station
operators were properly implemented. A trained and qualified staff for conducting
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radioactive waste effluent processing and release operations was maintained
(Section R5.1).
A trained and qualified staff for conducting the radiological environmental
monitoring program was maintained (Section R5.2).
Personnel directly involved in the transportation of radioactive material / waste were
adequately trained (Section R5.3).
The chemistry technical staff had experienced little change and no reduction during
the past 2% years (Section R6.1).
A lack of site ownership was observed for the radiological environmental monitoring
and meteorological programs (Section R6.2).
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Oversight of the radioactive waste effluent management programs was good
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(Section R7.1).
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Quality assurance audits of contractors were comprehensive and provided good
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evaluation and oversight of the contractors' performance (Section R7.2).
A good audit was performed which identified that self-assessments should be
performed. A good self-assessment was performed (Section R7.3).
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No independent review was performed of the licensee's solid radwaste program and
transportation of radioactive materials program following the implementation of the
revised transportation regulations (Section R7.4).
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iter, ort Details
Summarv of Plant Status
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The plant operated at full power during the entire inspection period. There were no
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operational occurrences that impacted the three inspections.
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111. Enoineerina
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E2
Engineering Support of Facilities and Equipment-
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E2.1
Updated Safety Analysis Report Review (USAR)
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Inspection Scope
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The inspectors reviewed selected topics presented in the USAR to ensure
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agreement with any commitments contained therein that pertained to these
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inspections,
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b.
Observations and Findinos
A recent discovery of a licensee that operated their facility in a manner contrary to
the USAR description, highlighted the need for a special focused review that
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compares plant practices, procedures, and/or parameters to the USAR descriptions.
While performing the inspections discussed in this report, the inspectors reviewed
the applicable portions of the USAR that related to the areas inspected. The
inspectors noted a discrepancy between the USAR wording and observed plant
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practices, procedures, and/or parameters. This discrepancy is discussed below.
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Volume I, Section 11.3, " Meteorology," states that the meteorological monitoring
system is powered locally from the 12.5 kV ring bus and from MCC "L" in the event
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of a loss of off-site power condition. Upon review of maintenance work orders, the
inspector discovered that the transfer switch supplying emergency power to the
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meteorological tower from the MCC "L" bus was out of service between
September 18,1995, and April 29,1996, a period greater than 7 months. This
was identified as a deviation from USAR commitments. (298/9621-01)
c.
Conclusion
A deviation from the commitments in the USAR was identified.
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IV. Plant Support
R1
Radiological Protection and Chemistry Controls
R 1.1
Radioloaical Waste Effluent Manaaement Proarams
a.
Inspection Scope (84750)
Implementation of the liquid and gaseous radioactive waste effluent management
programs, as described in the Technical Specifications and the Offsite Dose
Assessment Manual, including radioactive effluent waste processing, radioactive
effluent waste sampling and analyses, analyses sensitivities, analytical results,.
offsite dose results, and performance of required surveillance tests, were reviewed,
b.
Observations and Findinas
The inspector reviewed approximately 20 batch radioactive liquid waste effluent
release permits for the period January 1995 through August 1996. The inspector
determined that the processing, sampling, and analyses of radioactive liquid waste
effluents and the approval and performance of batch radioactive liquid waste
discharges were conducted in accordance with Technical Specificat:on
requirements. Quantities of radionuclides released in the radioactive liquid waste
effluents were within the limits specified in the Technical Specifications. Offsite
doses were calculated according to Technical Specification requirements and Offsite
Dose Assessment Manual methodologies and were within regulatory limits.
Technical Specification required analyses on composite samples of batch radioactive
liquid waste effluent releases for gross alpha, tritium, strontium-89, strontium-90,
and iron-55 were properly performed.
The inspector observed a chemistry technician collect a radioactive liquid waste
effluent sample from the floor drain tank on September 10,1996. The inspector
also observed a chemistry technician perform the chemistry analyses in the
chemistry laboratory (pH, conductivity, and turbidity) and the radiochemistry
analysis (principal gamma emitters) on the sample in the radiochemistry counting
f acility. The inspector noted that the chemistry technician used the following poor
sample handling techniques when collecting and analyzing the floor drain tank
sample.
The Marinelli beaker, the counting geometry for the sample, was used to
collect the sample directly from the sample point; therefore, the Marinelli
beaker was subjected to potential unwanted external contamination which
could give high erroneous analytical results.
Bare hands were used when handling the floor drain tank sample while
performing the chemistry analyses.
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The inspector also observed a chemistry technician prepare the radioactive liquid
waste effluent batch release permit. The inspector reviewed the liquid waste
effhet batch release permit and verified that the correct discharge valve lineup
rrmed by a station operator and that the alarm setpoints were properly set
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foi , v liquid radwaste effluent radiation monitor as required by the release permit.
All aspects of the floor drain tank discharge release were performed in accordance
with approved procedures.
Selected gaseous waste effluent sample analyses for samples from the elevated
release point off-gas vent, reactor building vent, augmented radwaste building vent,
and turbine building vent continuous releases for the period January 1995 through
August 1996 were reviewed. The inspector verified that the sampling, analyses,
and monitoring of the continuous discharges of radioactive gaseous effluents were
conducted in accordance with Technical Specification requirements and station
procedures.
Quantities of gaseous and airborne particulate radionuclides released were within
the limits specified in the Technical Specifications. Offsite dosec were calculated
according to Technical Specification requirements and Offsite Dose Assessment
Manual methodologies and were within regulatory limits. Noble gas samples were
collected and analyzed for principle gamma emitters and tritium in compliance with
Technical Specification requirements. Particulate effluent composite sample
analyses for gross alpha, strontium-89, and strontium-90 were performed for each
vent pathway in accordance with Technical Specification requirements.
The inspector observed a chemistry technician collect air particulate filter samples
and iodine charcoal cartridge samples from the elevated release point off-gas vent
sampler, the reactor building vent sampler, the augmented radwaste building vent
sampler, and the turbine building vent sampler associated with the respective
effluent ventilation systems' radiation monitors on September 10,1996,and
observed the collection of a noble gas sample from the elevated release point
off-gas vent radiation monitor RMP-RM-3B on September 11,1996. The chemistry
technician used forceps to handle the air particulate filter and used gloves while
collecting the noble gas sample. The inspector also observed a chemistry
technician collect four off-gas samples for analysis on September 11,1996.
However, the inspector noted that the chemistry technician used the following poor
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sample handling techniques when removing the iodine charcoal cartridge samples
from the sample holder devices and collecting the off-gas samples.
Bare hands were used while handling the radioactive charcoal cartridge
samples and the off-gas saraples. Gloves were not available.
The technician placed the air particulate filter samples and the charcoal
cartridge samples into individual plastic bags for transfer to the
radiochemistry counting f acility for analysis. However, the plastic bags were
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not sealed until they were taken to the chemistry laboratory where they were
heat sealed prior to analysis. This poor sample handling technique was
demonstrated when, following a sample collection, the inspector observed
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the technician pick up a plastic sample bag containing a charcoal cartridge
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sample, the charcoal cartridge slipped out of the bag into the sampling
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equipment carrying case, and was placed back into the plastic sample bag.
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Again, the charcoal cartridge sample was handled without gloves, and the
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potentially radioactive sample could have spread contamination in the
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sampling equipment carrying case.
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The inspector reviewed radiation work permits and procedures but did not identify
any specific requirement violations. The inspector's observations of poor sample
handling techniques were discussed with the chemistry supervisor during the
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inspection and at the exit meeting on September 13,1996. The licensee stated
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that they would evaluate the inspector's concerns and take appropriate actions.
The licensee reported no unplanned releases of radioactive liquid or gaseous waste
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during 1994 and 1995.
c.
Conclusions
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The liquid and gaseous radioatjve waste effluent management programs were
properly implemented. Poor sample handling techniques were used by the licensee
while collecting and handling a floor drain tank sample and the iodine ch
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cartridge samples from the elevated release point vent sampler, reactor uuilding vent
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sampler, augmented radwaste vent sampler, and turbine building vent sampler
associated with the respective effluent radiation monitors.
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R1.2 Safetv-Related Air Cleanina Systems
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a.
Inspection Scoce (84750)
Surveillance and test results for the safety-related air cleaning ventilation systems
testing program were reviewed to determine agreem ?nt with the commitments in
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the Updated Safety Analysis Report and compliance with the requirements in the
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Technical Specifications.
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b.
Observations and Findinas
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The inspector verified that the surveillance tests provided for 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 the in-place filter testing of the standby gas treatment
system and the control room emergency filter system. Since some of the
surveillance tests were only required to be performed at 18-month frequencies, the
inspector reviewed the last surveillance test results for each of the safety-related air
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cleaning ventilation systems named above and ensured that the previous two
surveillances had been performed as required at the 18-month frequency. The
in-place filter testing and activated charcoallaboratory surveillance tests were
performed in accordance with approved procedures by a contract laboratory, and all
test results were verified to be within Technical Specification limits. 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 was being tracked by the control room and the surveillance
coordinator.
c.
Conclusions
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The safety-related air cleaning ventilation systems conformed to the commitments
in the Updated Safety Analysis Report and met the Technical Specification
requirements. The safety-related air cleaning systems were tested in accordance
with Technical Specification requirements, and all test results were within Technical
Specification limits.
R1.3 Ra6oloaical Environmental Monitorina Proaram
a.
Inspection Scope (84750)
The radiological environmental monitoring program was reviewed to determine
compliance with the requirements in the Technical Specifications and the Offsite
Dose Assessment Manual.
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b.
Observations and Findinas
During this inspection, the inspector visited selected sampling stations and observed
sample collections. An environmental specialist collected samples at locations
specified by the Technical Specifications and the Offsite Dose Assessment Manual.
Sample collection and shipment logs were properly completed. Required quality
assurance audits and vendor audits were performed. Personnel knowledge and
performance was observed and training records were reviewed. A self-assessment
was performed which identified several improvement items to the radiological
environmental monitoring program.
The inspector observed that the licensee did not dedicate specific air sample media
holders for each air sampler in use. Instead, the inspector observed that the
technician removed the (used) air sample media holder from the air sampler station
and replaced it with a prepared (new) air sample media holder. The technician then
removed the sample collection media (e.g., the particulate filter and charcoal
cartridge) from the (used) air sample media holder, which now became the (new) air
sample media holder for the next air sampler station. Eventually, with subsequent
air sample media holder change outs, the air sample holders would have made their
way around to all the air sampler stations. To further illustrate, the air sample
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media holder used at the air sampler station with the highest possible deposition,
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after continued use, could then be used at the control air sampler station, the one
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with the lowest deposition. This cot.'d possibly contribute to a higher analysis
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result than actual background. The use of dedicated air sample media holders
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would reduce the possibility for cross contamination between subsequent sampling
periods. The inspector also noted that no calibration stickers were used on the air
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samplers to serve as a visual reminder of the next calibration due date. These items
were discussed with licensee during the inspection and at the exit meeting held on
September 13,1996. The licensee indicated that they understood the inspectors
observations. The inspector did not note any problems with the air sampler
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calibration records.
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The inspector reviewed the Technical Specifications, Offsite Dose Assessment
Manual, and environmental procedures. General Office management of the
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radiological environmental monitoring program was appropriate. The annual land
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use censuses were performed as required.
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c.
Conclusions
1.
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Overall, a good radiological environmental monitoring program was implemented in
accordance with Technical Specifications. All required activities contained in the
Technical Specifications and plant procedures were performed. Sampling locations
were as described in the Offsite Dose Assessment Manual. Dedicated air sample
media holders for each individual air sampler station were not used.
R1.4 Meteoroloaical Monitorina Proaram
a.
insoection Scope (84750)
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The meteorological monitoring program was reviewed to determine agreement with
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the recommendations in NRC Regulatory Guide 1.23 and compliance with the
commitments in Updated Safety Analysis Report, Volume l, Section ll.3,
" Meteorology."
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b.
Observations and Findinas
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The licensee utilized two towers with meteorologicalinstrumentation for obtaining
environmentalinformation. The instrumentation in use was as suggested in NRC
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Regulatory Guide 1.23 with all the required instrument channels. Semi-annual
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calibrations were performed on the meteorologicalinstruments as required.
The meteorological data was available in the control room and emergency response
f acilities. Data was stored by computer and sent daily, by electronic means, to the
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General Office, in Columbus, Nebraska, where an environmental specialist reviewed
the data and converted the data into the tables found in the Annual Operating
Report Radioactive Effluents. Data recovery rates for 1994 and 1995 were 99.1
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and 88.3 percent, respectively. Section R2.4 of this report discusses concerns
regarding the low data recovery rate for 1995.
c.
Conclusions
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A good meteorological monitoring program was implemented. Instrumentation on
the meteorological towers agreed with the guidance contained in NRC Regulatory
Guide 1.23.
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R2
Status of Radiological Protection and Chemistry Facilities and Equipment
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R 2.1 _ Radiochemistry Countina Facility and Radioactive Waste Effluent Processina
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Systems
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inspection Scope (84750)-
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The radiochemistry counting facility and associated analyticalinstrumentation were
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inspected to verify if adequate calibration and quality control programs were in
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place. The radioactive liquid and gaseous waste processing equipment were
inspected to ensure agreement with the Updated Safety Analysis Report.
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Equipment inspected in the radwaste building included the floor drain tank, two
waste monitor tanks, and their respective sample points,
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b.
Observations and Findinas
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The radiochemistry counting facility maintained sufficient state-of-the-art analytical
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instrumentation to perform the required radiochemistry analytical measurements of
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the radicactive waste effluents. The inspector reviewed the implementation of the
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calibration and quality control programs for the analyticalinstrumentation. The
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analyticalinstrumentation was properly maintained and calibrated.
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The liquid radioactive waste processing and storage systems were installed, as
described in the Updated Safety Analysis Report, and were operated in accordance
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with station procedures.
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The standby gas treatment system was installed, as described in the Updated
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Safety Analysis Report, and was operated in accordance with station procedures.
No major equipment or design modifications were made to the liquid or gaseous
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radioactive waste management systems during 1994,1995, and the first half of
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1996.
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c.
Conclusions
The radiochemistry counting facility was equipped with state-of-the-art analytical
instrumentation to perfor;n the required analyses. The analyticalinstrumentation
was properly maintainea, tested, and calibrated. Liquid and gaseous radioactive
waste management systems were installed and operated properly,
R2.2 Liauid and Gaseous Effluent Radiation Monitors
a.
Inspection Scope (84750)
The liquid and gaseous effluent radiation monitors were inspected for operatic a,
calibration, and reliability.
b.
Observations and Findinas
The inspector reviewed the liquid and gaseous radioactive waste effluent radiation
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monitor source check, channel chuck, channel functional test, and channel
calibration records, for the time period January 1995 through August 1996, to
determine agreement with the surveillance requirements specified in Technical
Specification 3/4.21. A.1, Table 4.21.A.1 and Technical Specification 3/4.21.A.2,
Table 4.21.A.2. All records reviewed indicated that the liquid and gaseous
radioactive waste effluent monitoring instrumentation was properly maintained,
tested, and calibrated in agreement with the surveillance requirements specified in
the Technical Specifications.
c.
Conclusion
All liquid and gaseous effluent radiation monitoring instrumentation was operable
and properly maintained, tested, and calibrated in agreement with the surveillance
requirements specified in the Technical Specifications.
R2.3 Environmental Monitorina Eauipment
a.
inspection Scoce (84750)
Selected environmental sampling stations and preparation and storage facilities used
by the licensee were inspected.
b.
Observations and Findinas
The inspector observed the facilities used by the licensee, including the
environmental media sample storage and preparation areas. The preparation / storage
area was equipped with all the necessary chemicals, spare equipment, and supplies
to perform the required radiological environmental monitoring program activities.
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The inspector toured the following types of sampling sites with the environmental
technician and the environmental specialists: air particulate, vegetation,
thermoluminescent dosimeter, and milk. The inspector noted that the air samplers
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in service were calibrated and operational. A timing device was used at each air
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sampler to track its operation. Environmental samples were prepared for shipment
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to a vendor laboratory for analysis.
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c.
Conclusions
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The licensee maintained sufficient supplies and spare environmental sampling
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equipment to perform the activities described in the Technical Specifications.
Environmental monitoring stations were properly maintained, and the equipment
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was operable and properly calibrated.
R2.4 Meteoroloaical Monitorina Eauipment
a.
Inspection Scope (84750)
The meteorologicalinstrumentation at the meteorological towers was inspected, and
the associated calibration records were reviewed.
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b.
Observations and Findinns
The licensee maintained two meteorological towers with monitoring
instrumentation. The 100-meter tower was equipped with wind speed, wind
direction, and temperature sensing instrumentation at the 10,60, and 100-meter
levels. The 10-meter tower was equipped with the same instrumentation at the
10-meter level. Calibration records showed that the instrument channels were
calibrated at the required frequencies.
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The inspector noted that the instrumentation agreed with the recommendations in
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NRC Regulatory Guide 1.23 and the licensee's Updated Safety Analysis Report.
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However, a low data recovery rate, under the 90 percent recommendation
suggested in NRC Regulatory Guide 1.23, was obtained for 1995.
The inspector reviewed maintenance wc.rk order listings for the meteorological
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tower instrumentation and noted that the average length of time for instrument
inoperability was about 120 days. This corresponded to a priority level 3 work
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order. As reported in the Annual Operating Report Radioactive Effluents,
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meteorological data for several months was not available due to the length of time
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the meteorological tower instrumentation was out of service. This is of concern
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because industry averages for meteorological data recovery are 97-98 percent. An
Inspection Followup item was opened to review the licensee's efforts in maintaining
the meteorological towers' instrumentation operable and increasing the
meteorological data recovery rate. (298/9621-02)
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c.
Conclusions
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Meteorological monitoring instrumentation channels were calibrated at the proper
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frequencies. Meteorological tower instrumentation maintenance was poor, which
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contributed to a low data recovery rate. An Inspection Followup item was identified
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regarding the licensee's meteorological tower instrumentation maintenance program.
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R3
Radiological Protection and Chemistry Procedures and Documentation
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R3.1
Radioactive Waste Effluent Procedures, Offsite Dose Assessment Manual, Annual
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Operatina Report Radioactive Effluents, Annual Radioloaical Environmental
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Operatina Report, and Radioloaical Environmental Monitorina imolementina
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Procedures
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a.
Insoection Scope (84750)
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Procedures for the sampling, analysis, and release of radioactive liquid and gaseous
waste effluents, and procedures for the implementation of the radiological
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environmental monitoring program were reviewed. Revisions to the Offsite Dose
Assessment Manual were reviewed. The annual reports concerning radioactive
waste effluent releases and the radiological environmental monitoring program were
reviewed for omissions, obvious mistakes, anomalous measurements, observed
biases, trends in the data, and laboratory inter-comparisons.
b.
Observations and Findinas
The inspector verified that the procedures for batch release of liquid radioactive
waste effluents provided proper guidance regarding sampling, recirculation,
analyses, release limits, monitoring, and approvals.
The radiological environmental monitoring program implementing procedures
described the responsibilities for collection, documentation, and shipment of
environmental media samples collected around the station. The procedures were
written with sufficient detail to effectively conduct the required radiological
environmental monitoring program activities. The inspector reviewed the licensee's
sample collection procedures and identified no concerns.
The Annual Operating Report Radioactive Effluents for 1994 and 1995 included
meteorological data and changes to the Offsite Dose Assessment Manual, as
required. The reports were written in the format described in NRC Regulatory
Guide 1.21, Revision 1, June 1974, and contained the information required by the
Technical Specifications.
Summaries of the quantities of radioactive liquid and gaseous effluents released to
the environment, and their associated doses to members of the public for 1994 and
1995, were properly documented in the annual reports.
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No unplanned releases of radioactive liquid or gaseous waste were reported during
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1994,1995, and the first half of 1996.
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The inspector reviewed the radiological environmental sample location changes to
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the Offsite Dose Assessment Manual, which were reviewed and approved by the
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Station Operations Review Committee during 1994 and 1996. The changes were
documented in the appropriate Annual Operating Report Radioactive Effluents as
required by the Technical Specifications.
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The Annual Radiological Environmental Operating Reports for 1994 and 1995
included the sampling results for those years and indicated that sampling was
performed as required. Any discrepancies or missed samples were reported. The
inspector noted that sampling, analyses, and reporting requirements were met. The
annualland use censuses were conducted as required, and the results were
included in the respective annual reports.
c.
Conclusions
Procedures established to implement the liquid and gaseous radioactive waste
effluent management programs provided proper guidance. The radioactive waste
effluent management programs were properly implemented. Good radiological
environmental monitoring implementing procedures with sufficient detail were in
use. Changes to the Offsite Dose Assessrnent Manual were properly documented.
Excellent Annual Operating Report Radioactive Effluents and Annual Radiological
Environmental Operating Reports for 1994 and 1995 were submitted in a timely
rnanner and contained the required information presented in the required format.
R3.2 Review of Shiocina Docurnentation
a.
Insoection Scope (86750)
I
Selected documentation associated with shipments were reviewed to determine that
the licensee's procedures complied with the applicable regulations and that the
shipping records indicated that shipments were made in accordance with the
licensee's procedures. The inspector reviewed seven shipment packages.
b.
Observations and Findinas
Documentation retained by the licensee contained copies of the shipping documents
and supporting information for the shipment. The calculations associated with
characterizing the shipment were performed by hand. Data for the calculations was
compared with the tabulated data found in the regulations. No discrepancies were
noted.
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The inspector performed independent calculations to verify the licensee's
calculations for selected shipments. No discrepancies were noted for the shipments
.
J
reviewed.
}
In Problem identification Report 2-00564, the licensee identified an error in
'
determining which isotopes should be reported on shipping documents and labels.
This error was associated with the "95 percent rule" described in
,
I
k
49 CFR 173.443(c). This error affected the documentation for 6 individual
j
shipments. The licensee initiated corrective actions upon discovery of the error and
implemented sufficient controls to prevent recurrence.
,
l
During the review of the shipping documents, the inspector noted that there were
j
many instances where required notations and supplemental calculations were
entered onto the shipping documents by hand. The shipping documents were
i
prepared from attachments to the shipoing procedure. The additional notations and
supplemental calculations were not included as part of the procedure. During
!
discussions regarding this observation, the licensee stated that the attachments
I
would be revised, as needed, to include the appropriate notations and provide for
l
the supplemental calculations.
)
l
The licensee included a form similar to NRC Form 3 as part of the emergency
I
response information provided to carriers. This form indicated that the NRC regional
j
offices could be reached 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day by calling the NRC regional phone
j
numbers. The inspector informed the licensee that the NRC regional office phones
were not staffed outside of normal working hours. Furthermore, emergency
i
l
response communications could be more readily handled at any time of the day
!
through the NRC Operations Center. The licensee agreed to update the form to
i
provide the emergency contact number for the NRC Operations Center.
1
The licensee included copies of the recipient's license as part of the supporting
4
I
documentation for the shipment. The inspector discussed the process for reviewing
j
recipients' licenses to ensure that recipients were properly licensed to receive
radioactive materials. Two situations were identified where the licensee was
l
potentially vulnerable:
!
!-
If a recipient was licensed to possess a stated quantity of material, no
confirmation was made to ensure that the shipment of material would not
result in the license limit being exceeded,
a
i
If a recipient (state licensee) was issued a letter of extension due to delays in
license processing, and the letter did not contain an expiration date, no
i
further confirmation was made to ensure that the process was continuing
l
and that the extension was valid,
t
The licensee stated that changes to the procedure would be made to include
,
additional guidance for the above cases.
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c.
Conclusion
Programmatic controls and procedures for shipment of radioactive material / waste
were adequate.
R3.3 Transportation of Low Specific Activity Materials and Surface Contaminated Objects
a.
Inspection Scope (Tl 2515/133)
The licensee's procedure for the processing and packaging of low specific activity
material and surf ace contaminated objects were reviewed.
b.
Observations and Findinas
The inspector noted that the licensee made shipments of radioactive materials
classified as surface contaminated objects. The licensee's procedures addressed
how the assessment of contaminated surfaces for inaccessible areas was to be
accomplished. The inspector informed the licensee that their assessment process
would be presented to the NRC program office for further review.
The various types of shipping packages that were acceptable for shipping low
specific activity materials and surface contaminated objects were compared with
those listed in Department of Transportation regulations. The inspector verified the
accuracy of the liceusee's procedure. The inspector noted that the licensee
permitted the use of strong-tight containers constructed and used prior to
April 1,1996. The licensee included a statement in the shipping documentation
packages for shipments using these containers that qualified them for use based
upon prior use.
The inspector reviewed documentation for selected shipments made since
April 1,1996. The documentation was reviewed to ensure that required
information was present and that, when needed, the isotopes reported on the
shipping papers satisfied the "95 percent rule." The licensee's calculation process
was verified to be accurate.
c.
Conclusion
The procedure for shipping low specific activity materials and surface contaminated
objacts was consistent with regulatory requirements.
R3.4 Use of International System of Units (SI) (Tl 2515/133)
The licensee incorporated the use of Si units into the radioactive material shipping
procedure. SI units were required for activities and radiation measurements. The
inspector noted that the licensee's current practice was to use the standard units of
curies and millirem. Since mandatory use of SI units for radiation units does not
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become effective until April 1,1997, the licensee indicated that the procedure
'
would be modified to allow the current practice until April 1,1997.
R3.5 Expansion of the Radionuclide List and Chanaes in Radionuclide Limits
(Tl 2515/133)
The inspector reviewed the licensee's use of the radionuclide table of A,/A values
2
to assure that packages did not exceed the allowable radioactivity limits. The
licensee used a manual calculation process that referenced the table in the Code of
Federal Regulations. This information was incorporated into implementation of the
"95 percent rule" for listing radionuclides on shipping papers in accordance with
49 CFR 173.433. No discrepancies were noted.
R3.6 Classification of Fissile Material (Tl 2515/133)
The inspector reviewed the licensee's procedures associated with the use of the
transport index and special controls for the prevention of criticality in transportation
of fissile material. These were consistent with the new fissile material
requirements.
R4
Staff Knowledge and Performance
R4.1
Chemistry Staff
a.
Inspection Scone (84750)
The chemistry supervisor, chemist, chemistry crew leader, chemistry technicians,
and station operators were interviewed with regard to regulatory and Technical
Specification requirements for the implementation of the liquid and gaseous
radioactive waste effluent management programs.
b.
Observations and Findinas
Chemistry personnel and station operators were knowledgeable of the programmatic
procedures, Technical Specification requirements, and regulatory requirements and
maintained a high level of performance. Batch radioactive liquid waste effluent
releases and continuous radioactive gaseous waste effluent releases were properly
performed during the January 1995 through August 1996 time period.
c.
Conclusions
Chemistry personnel and station operators had an excellent understanding of the
radioactive liquid and gaseous waste management procedures, Technical
Specifications, and regulatory requirements.
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R4.2 Environmental Staff
a.
Inspection Scope (84750)
1
The inspector observed and held discussions with personnelinvolved with the
implementation of the radiological environmental monitoring program,
b.
Observations and Findinas
The inspector noted that good sample handling techniques were used by the
environmental specialist to maintain sample integrity during collection and packaging
of samples for shipment. Activities observed were conducted in an orderly fashion.
Good knowledge of environmental sampling and implementing procedures was
.
maintained by the environmental staff.
c.
Conclusion
The knowledge and performance of the environmental technician responsible for
'
implementing the radiological environmental monitoring program activities were
good.
R5
Staff Training and Qualification
R5.1 Trainina and Qualification of Chemistry Personnel and Radwaste Station Operators
a.
Inspection Scope (84750)
Training and qualification programs for chemistry technicians and radwaste station
operators involved with conducting the radioactive waste effluent management
programs were reviewed. Training and qualifications of the chemistry technicians
and radwaste station operators were verified.
b.
Observations and Findinas
The inspector verified that all but one recently hired chemistry technician had
completed all of the training required to perform radioactive waste management
program activities.
The inspector verified that 17 radwaste station operators were trained and qualified
to conduct radioactive waste effluent batch releases and operate radioactive waste
processing equipment.
c.
Conclusions
Training and qualification programs for the chemistry technicians and the radwaste
station operators were properly implemented. The chemistry department and the
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radwaste operations department had well trained and qualified staffs for conducting
radioactive waste effluent processing and release operations.
R5.2 Trainina and Qualification of Environmental Personnel
a.
Inspection Scoce (84750)
Training and qualification programs for the technical staff responsible for
implementing the radiological environmental monitoring program were reviewed.
b.
Observations and Findinas
No formal training and qualification program or procedure were currently developed
for the environmental technicians and environmental specialist. This was identified
during the licensee's self-assessment (see R7.3). However, the licensee had
documented any classroom training and on-the-job training received. Training
Program Description (TPD-0703) was developed and approved to track the training
and on the-job tasks completed by the environmental staff. The inspector did not
find any concerns with the training records reviewed.
c.
Conclusions
The radiological environmental monitoring program was implemented by qualified
personnel. The inspector determined that the experience, training, and working
knowledge of the environmental staff were adequate to implement the radiological
environmental monitoring program.
R5.3 Trainina and Qualification of Radiation Protection Radwaste Personnel
a.
Inspection Scope (Tl 2515/133)
The training, knowledge, and performance of radwaste workers and supervisors
responsible for the transportation activities were reviewed to determine that the
changes and updates to the regulations were included in the training and
qualification program,
b.
Observations and Findinas
Personnel within the radwaste organization had attended training regarding the
revised regulations. This training was provided by a vendor. This training satisfied
the 49 CFR Part 172, Subpart H, requirement that each hazmat employer provide
initial and periodic training to its hazmat employees.
The licensee had designated shippers as part of individual position descriptions.
The inspector reviewed training records associated with personnel directly involved
with the preparation of shipments. The inspector noted that there was not a
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specific task qualification process for these individuals that reflected expiration of
j
recurring training. The inspector discussed retraining activities with responsible
j
training personnel. As a followup action, the licensee initiated changes to ensure
]
that training cycles were proper'y tracked. The inspector verified that there were no
j
individuals who had participated in the transfer, packaging, and transport of
radioactive materials that were not currently trained as needed.
..
Conclusion
c.
Personnel directly involved in the transportation of radioactive material / waste were
l
adequately trained.
i
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R6
Radiological Protection and Chemistry Organization and Administration
i
R6.1 Chemistry Oraanization and Staffino
.
a.
Inspection Scoce (84750)
l
The organization, staffing, and assignment of the radioactive waste effluent
management program responsibilities were reviewed. Administrative and
'
departmental procedures were reviewed for the assignment of responsibilities for
j
the management and implementation of the radioactive waste effluent management
a
programs.
!
!,
b.
Observations and Findinas
The inspector verified that the chemistry and radwaste operations organizations and
i
staff were responsible for the implementation of the radioactive waste effluent
l
management program. The inspector determined that the duties and responsibilities
i
'
for implementing the radioactive waste effluent management program, as specified
i
in the procedures, were implemented.
I
The inspector reviewed the staffing of the chemistry and radwaste operations
i
organizations and determined that they were adequately staffed. There had been
j
very little change and no reduction in technical staff within the chemistry technical
l
staff during the past 2% years.
c.
Conclusions
]
{
The chemistry and radwaste operations organizations and staffing met Technical
j
Specification requirements. The chemistry technical staff had experienced little
j
change and no reduction during the past 2% years.
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R6.2 Environmental Monitorina Oraanization and Staffina
a.
Insoection Scope (84750)
The organization, staffing, and assignment of the radiological environmental
monitoring program responsibilities were reviewed.
b.
Observations and Findinas
The General Office in Columbus, Nebraska, was responsible for implementing the
radiological environmental monitoring program. The radiological environmental
monitoring program was implemented in accordance with Technical Specification 3.21, the Offsite Dose Assessment Manual, and Environmental Procedure 1.0,
"CNS Radiological Environmental Monitoring Program," Rev.12, August 9,1996.
Organizational charts clearly outlined the number of licensee staff and positions.
The General Office performed well in implementing its duties in the environmental
and meteorological programs. However, a lack of plant site ownership existed for
these programs. The General Office personnel did not have a site contact to help
expedite and work problem and maintenance issues related to these programs. Site
ownership is desirable to help ensure that station regulatory commitments are met.
The lack of site ownership may have been a contributor to the meteorological tower
maintenance problems as discussed in Section R2.4. This issue was discussed with
the licensee at the exit meeting on September 13,1995. The licensee indicated
that they understood the inspectors concerns.
c.
Conclusions
The General Office performed wellin implementing the radiological environmental
monitoring program. A lack of site ownership was observed for the radiological
environmental monitoring and meteorological programs.
R7
Quality Assurance in Radiological Protection and Chemistry Activities
R7.1
Radioactive Waste Effluent Quality Assurance Proaram
a.
Inspection Scope (84750)
The quality assurance audit and surveillance programs regarding the radioactive
waste effluent management program activities were reviewed. The review included
the audit and surveillances performed between 1994-1996.
b.
Observations and Findinas
The review of the quality assurance audit schedules indicated that the audits of the
radiological controls, which was a combined audit of the radiation protection
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,
program, radioactive waste effluent program, radiological environmental monitoring
program, and radwaste program, were scheduled on a 24-month frequency during
l
1994,1995, and 1996,in accordance with Technical Specifications 6.2.7.b, and
6.2.7.h. The audit was scheduled in compliance with Technical Specification audit
frequency requirements.
,
4
Reports of the quality assurance audit and surveillances, performed during the
j
period January 1994 through August 1996, of the areas related to the performance
of the radioactive waste effluent manageraent programs were performed in
a
accordance with the quality assurance procedures by qualified auditors and assisted
j
by technical specialists. The audit and surveillances of the radioactive waste
effluent program were of good quality and provided satisfactory oversight and
l
evaluation of the licensee's performance in implementing the radioactive waste
!
effluent management program and met the Technical Specification requirements.
?
(
c.
Conclusions
.
Oversight of the radioactive waste effluent management programs was good. The
i
quality assurance audit and surveillances of the radioactive waste effluent
i
management program activities were technically comprehensive and provided good
program evaluation and oversight.
l
4
R7.2 Quality Assurance Proaram for Contractors
}
{
a.
Insoection Scope (84750)
)
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The quality assurance audit program regarding contractors performing surveillance
j
activities involving the radioactive waste effluent program, safety-related air
l
cleaning ventilation systems, and radiological environmental monitoring program
i
were reviewed.
!
I
b.
Observations and Findinas
i'
The licensee used a contractor laboratory to perform required radiochemistry
j
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analyses of radioactive waste effluent composite samples, another contractor to
l
perform in-place filter testing and laboratory charcoal adsorber analyses on the
!
station's safety-related air cleaning ventilation systems, and a third contractor
j
laboratory to perform radiochemistry analyses on environmental media samples. An
audit of the radiochemistry laboratory, used to perform radiochemistry analyses of
4
!
radioactive waste effluent samples, was performed by a Nuclear Procurement issues
!
Committee (NUPIC) audit team, led by Baltimore Gas and Electric Company on
i
October 31 through November 2,1994. An audit of the safety-related air cleaning
!
ventilation systems' filter testing contractor was performed by a NUPIC audit team,
'
led by Washington Public Power Supply System on November 15-17,1994. An
audit of the radiochemistry laboratory, used to perform radiochemistry analyses of
f
environmental media samples, was performed by a NUPIC audit team, led by Wolf
l
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Creek Operating Corporation on August 1-5,1994. The licensee used these three
audits to evaluate the performance of the three contractors in performing their
respective analytical functions and to retain their current status on the licensee's
qualified suppliers list. The inspectors reviewed the audits performed on the three
contractors and determined that the audits were satisfactory to evaluate the
contractors' abilities to perform their respective Technical Specification required
analyses and surveillance activities,
c.
Conclusions
Quality assurance audits of contractors were comprehensive and provided good
evaluation and oversight of the contractors' performance.
R7.3 Radioloaical Environmental Monitorina Quality Assurance Proaram
a.
Inspection Scope (84750)
A quality assurance audit report concerning the radiological environmental
monitoring program was reviewed for scope, thoroughness of program evaluation,
and timely followup of identified deficiencies.
b.
Observations and Findinas
The inspector reviewed the results of the audit performed in November 1994 by the
licensee, including the audit plans and schedules. The audit was thorough and
covered all aspects of the radiological environmental monitoring program. An
improvement item was identified during this audit, which suggested that the
environmental group perform self-assessments.
The inspector determined that the quality assurance personnel assigned to perform
this audit had appropriate knowledge and experience, which enabled them to
properly assess performance and to identify problems. The audit team consisted of
licensee personnel and technical specialists.
A self-assessment of the radiological environmental program was performed
April 15 through May 21,1996. This self-assessment identified several
improvement items in the implementation of the radiological environmental
monitoring program.
c.
Conclusions
A good audit was performed which identified that self-assessments should be
performed. The audit was performed by qualified auditors, which included
assistance by technical specialists. The audit was performed at the required
frequency. A good self-assessment was performed.
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R7.4 Radwaste Pronram Assessments
a.
Inspection Scope (86750)
Audits, curveillances, and assessments of the solid radwaste program were
reviewed.
b.
Observations and Findinas
The inspector reviewed the licensee's quality assurance audit of the radiation
protection program which was performed in November 1994. This audit included a
review of radioactive waste processing and radioactive waste and material shipping
activities. The audit was very broad in scope and the sheer volume of the report
tended to deemphasize the report findings. Even so, the findings were well based
and reflected the expertise of the personnel performing the audit.
Since the previous inspection in this area, the licensee reduced the quality
j
assurance oversight of radwaste/ radioactive materials shipments from 100 percent
to a less frequent sample. This reduction in quality assurance oversight was based
upon the lack of substantial findings from quality assurance surveillances of the
solid radwaste program and the transportation of radioactive materials program.
The inspector noted that the last quality assurance surveillance related to the
transportation of radioactive materials was in March 1996. The inspector discussed
the changes to the regulations, programs, procedures, equipment, etc., as well as
the importance of industry events that may have affected the licensee's
assumptions to reduce the quality assurance surveillance frequency. The licensee
had not performed a formal review of this decision; therefore, no change to the
current quality assurance surveillance frequency was made.
The inspector pointed out that since the major changes in the transportation
regulations, effective April 1,1996, the licensee had not performed quality
assurance surveillances associated with the performance of the solid radwaste
program and the transportation of radioactive materials program. The licensee
stated that priorities were in other program areas. Since no major transportation
issues had been identified, no immediate changes were planned.
The inspector interviewed the individual that the licensee identified as the in-house
expert for radiation protection and solid radwaste programs in the quality assurance
department. This individual did not have applied experience in the transportation of
radioactive materials, nor had he received any training associated with the new
transportation regulations.
The licensee performed a self-assessment of the radiation protection program during
the week of March 25,1996. As part of this self-assessment, the licensee used
expertise from another nuclear power facility to review the solid radwaste program.
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The self-assessment contained numerous comments and recommendations
associated with the licensee's solid radwaste program. The licensee was tracking
the implementation of these comments and recommendations.
1
.
While the self-assessment was very good, the inspector noted that the
self-assessment was performed prior to the implementation of the revised
'
transportation regulations.
c.
Conclusions
There was no independent review of the licensee's radwaste program following the
implementation of the revised transportation regulations. Additional assessments by
the licensee would benefit the solid radwaste and transportation of radioactive
materials programs,
i
.
V. Manaaement Meetinas
X1
Exit Meeting Summary
The inspectors presented the results of the three inspections to members of licensee
management at the conclusion of the inspection on September 13,1996. The
licensee acknowledged the findings presented.
The inspectors asked the !icensee whether any materials examined during the
inspections should be considered proprietary. No proprietary information was
identified.
~
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,
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Bauer, Environmental Specialist, General Office
R. Beilke, Radiological Support Supervisor, Radiation Protection
M. Bennett, Supervisor, Nuclear Licensing
D. Billesbach, Manager, Work Control
S. Bray, Assessment Supervisor, Quality Assurance
T. Chard, Assistant Manager, Radiation Protection
T. Chinn, Temporary Environmental Technician
K. Fike, Chemist
<
M. Hale, Manager, Radiation Protection
H. Hasenkamp-Gibbs, Acting Environmental Supervisor, General Office
J. Humphrey, Lead licensed Instructor, Nuclear Training
J. Kuttler, Radwaste Specialist, Radiation Protection
D. Madsen, Licensing Engineer, Licensing
R. Mcdonald, Supervisor, Chemistry
R. Nyffeler, Acting Environmental Manager, General Office
J. Peaselee, Surveillance Coordinator
M. Peckham, Plant Manager
R. Sessoms, Senior Manager, Quality Assurance
G. Smith, Operations Manager, Quality Assurance
D.'Snyder, Chemistry Instructor, Nuclear Training
E. Stukenholtz, Instrument and Controls Technician
C. Taylor, Licensing Specialist, Licensing
J. Teton, Crew Leader, Chemistry
B. Toline, Audit Supervisor, Quality Assurance
K. Walden, Manager, Environmental Policy, General Office
NRC
M. Miller, Senior Resident inspector
LIST OF INSPECTION PROCEDURES USED
Radioactive Waste Systems; Water Chemistry; Confirmatory
Measurements and Radiological Environmental Monitoring
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
Tl 2515/133
Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
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.
9
-2-
LIST OF ITEMS OPENED AND CLOSED
Opened
50-298/9621-01
NOD
USAR Commitment
50-298/9621-02
IFl
Meteorological tower Maintenance
LIST OF ACRONYMS USED
International System of Units
Nuclear Procurement issues Committee
LIST OF DOCUMENTS REVIEWED
Documents Reviewed During the Radioactive Waste Effluents Management inspection
Oraanization Charts
Radiological Department - June 1996
Operations D epartment - June 1996
Nuclear Training Department - June 1996
Quality Assurance Division - June 1996
Quality Assurance Documents
Internal Audit Schedule - 1994
Internal Audit Schedule - 1995
Internal Audit Schedule - 1996
Quality Assurance Audits
Quality Assurance Audit 94-23, ASP-402, " Radiological Controls," Part 2,
October 11 through December 27,1994
Quality Assurance Audit 95-13, ASP-406, " Chemistry," July 24 through August 15,1995
..
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Quality Assurance Surveillances
1
l
Quality Assurance Surveillance, OAC-95153,"ERP Kaman Monitor Functional Test,"
May 17,1995
,
Quality Assurance Surveillance, SC-406-02," Radiochemistry Analysis," May 17,1995
Quality Assurance Surveillance, OE-9505, " Service Water Operation," January 20,1995
Vendor Audits
NUPIC Joint Quality Assurance Audit of TMA/ Richmond, October 31 through
November 2,1994
NUPIC Joint Quality Assurance Audit of NCS Corporation, November 15-17,1994
Procedures
Administrative Procedures
0.2
" Station Organization and Responsibility," Revision 12
0.17
" Selection and Training of Station Personnel," Revision 21.1C1
Operations Procedure
2.5.2.3
"Radwaste High Conductivity Liquid Waste Floor Drain Sample Tank Fluid
Transfer," Revision 38.1
i
Chemistry Procedures
8.2.1
" Chemistry Analysis and Instrument Calibration Schedule," Revision 19.1
8.4
" Routine Sampling and Sample Valve Control," Revision 9.1
8.8.4
"Off-Gas Grab Samples isotopic Analysis," Revision 11.1
8.8.8
" Particulate, lodine, and Noble Gas Sample Collection for Effluent Monitors,
Control Building Intake," Revision 15.1
8.8.11
" Liquid Radioactive Waste Discharge Authorization," Revision 15
8.11.1
" Effects Program," Revision 6
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Trainina Documentation
Training Program Description TPD-0412, " ANSI Chemistry Technician," Revision 5.01,
dated May 1,1996
Training Program Description TPD-9208," Radioactive Liquid Discharge Analysis,"
Revision 0, dated August 1,1995
Training Program Description TPD 9211," Perform Analysis of Liquid Radwaste
Composite," Revision 0, dated August 1,1995
Training Program Description TPD-9213, " Operate Counting Room Instruments,"
' Revision 0, dated July 31,1995
Training Program Description TPD-9306,"Obtain Sample from Sample Rack," Revision 0,
dated August 1,1995
Training Program Description TPD-9317," Steam Jet Air Ejector Off-Gas Analysis,"
Revision 0, dated August 1,1995
Training Program Description TPD-9 401," Radioactive Particulate and lodine Sample,"
Revision 0, dated July 31,1995
l
Training Program Description TPD-0402, " Noble Gas Samples," Revision 0, dated
l
July 31,1995
Training Program Description TPD-9 409," Steam Jet Air Ejector Monitor Source Check,"
Revision 0, dated July 31,1995
j
Training Program Description TPD-9411," Perform Functional Test of Kaman Monitor,"
Revision 0, dated July 31,1995
Training Program Description TPD-9803," Calibrate Steam Jet Air Ejector Radiation
l
Monitor," Revision 0, dated July 31,1995
l
l
Training Program Description TPD-9804, " Calibrate Kaman Vent Monitor," Revision 0,
dated July 31,1995
Training Program Description TPD-9805," Calibrate REC and SW Process Radiation
Monitor," Revision 0, dated July 31,1995
Training Prograrn Description TPD 9806," Calibrate Liquid Radwaste Monitor," Revision 0,
j
dated July 31,1995
Training Program Description TPD-9814, " Tritium Analysis," Revision 0, dated
July 31,1995
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Training Program Description TPD-0201," Station Operator," Revision 11, dated
,
l
March 4,1996
I
l
Lesson Plan, INT 014-11-01," Tritium Samples," Revision 3.01
Lesson Plan, OTH0009-01-01," Chemistry Surveillance Methods," Revision 1.01
'
Lesson Plan, INT 013-02-01,"Kaman Monitor Samples," Revision 2.02
Lesson Plan, COR012-04-01," Gaseous Effluent Sampling," Revision 2.01
Lesson Plan, COR001-19-01,"Radwaste System," Revision 8
Lesson Plan, SKLOO9-01-01,"Radwaste Building OJT/TPE Qualification Card,"
Revision 6.03
Surveillance Tests
6.HV.101
" Control Room Ventilation," Revision 0.1
6.HV.103
" Control Room Emergency Fan Filter Train Differential Pressure Test,"
Revision 0
,
6.HV.104
" Control Room Emergency Fan Charcoal and HEPA Filter Leak Test,
Fan Capacity Test, and Charcoal," Revision 0
6.HV.105
" Control Room Envelop Pressurization Test," Revision 4
6.HV.301
" Turbine Building Ventilation Flow Monitors Calibration and Functional
Test," Revision O
6.HV.302
" Reactor Building Ventilation Flow Monitor Calibration and Functional
Test," Revision OC1
6.HV.304
"Radwaste Building Ventilation Flow Monitor Calibration and
Functional Test," Revision 0
6.OG.301
"Off-Gas System Auto Isolation Functional Test," Revision 1
6.OG.303
"Off-Gas Flow Monitor Calibration," Revision 0
6.PRM.301
"Off-Gas Radiation Monitor Source Check Test," Revision 0.2
i
6.PRM.302
"Off-Gas Radiation Monitor Linearity Test and Efficiency
Determination," Revision 0
6.PRM 303
"SW Radiation Monitor Source Check," Revision 0
6.PRM.304
"SW Radiation Monitor Source Check and Function-
"est,"
Revision 1.1
6.PRM.305
"SW Radiation Monitor Calibration Check and Instrument Channel
Test," Revision 0
6.PRM.306
" Liquid Radwaste Effluent Flow Monitor Cctibration and Functional
Test," Revision 0
6.PRM.307
" Liquid Radwaste Effluent System Functional and Logic Test,"
Revision 0
6.PRM.308
" Liquid Radwaste Effluent System Calibration Test," Revision 0
.
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6.PRM.309
"ERP Kaman Monitor Functional Test," Revision 0.1C1
6.PRM.310
"ERP Kaman Monitor Calibration," Revision 0
6.PRM.312
" Reactor Building Kaman Monitor Functional Test," Revision OC1
6.PRM.313
" Reactor Building Kaman Monitor Calibration," Revision 0
6.PRM.314
" Turbine Building Kaman Monitor Functional Test," Revision OC1
6.PRM.315
" Turbine Building Kaman Monitor Calibration," Revision 0
6.PRM.318
" Control Room Air Sampling System Functional and Logic Test,"
Revision 0.1
6.PRM.319
"RW/ARW Kaman Monitor Functional Test," Revision OC1
6.PRM.320
"Radwaste Building Kaman Monitor Calibration," Revision 0
6.10G.301
" Augmented Off-Gas Hydrogen Monitor Calibration and Functional,"
Revision 0
6.1 PRM.304
" Reactor Building Ventilation Radiation Monitor Calibration and
Functional Test / Source Check," Revision 0.1
6.1 PRM.305
"Off-Gas Radiation Monitor Calibration and Functional Test,"
Revision 1C1
6.1 PRM.306
"Off-Gas Radiaion Monitor Functional Test," Revision 2
6.1 PRM.311
" Reactor Building Ventilation Radiation Monitor Source Check,"
Revision 0.1
6.1 SGT.101
"A SGT Filter Differential Pressure, Heater Output, and Fan Motor
Running Current Test," Revision 0
'
6.1 SGT.301
"SGT Operability Test /Off-Gas Flow Monitor Functional Test,"
Revision 0.1
j
6.1 SGT.401
"SGT A Charcoal Filter Leak Test, Fan Capacity Test, SGT B Cooling
i
'
Flow Test and Check Valve IST," Revision 0
6.1 SGT.501
"SGT A HEPA Filter and Component Leak Test," Revision 0.1
6.1 SGT.601
"SGT A Charccal Filter Carbon Analysis - Methyl lodide," Revision 0
6.1 SJAE.301
" Steam Jet Air Ejector Flow Monitor Calibration and Functional Test,"
Revision 0
6.2OG.301
" Augmented Off-Gas Hydrogen Monitor Calibration and Functional,"
Revision 0
6.2PRM.304
" Reactor Building Ventilation Radiation Monitor Calibration and
Functional Test / Source Check," Revision 0.1
6.2PRM.305
"Off-Gas Radiation Monitor Calibration and Functional Test,"
Revision 1C1
6.2PRM.306
"Off-Gas Radiation Monitor Functional Test," Revision 3
6.2PRM.311
" Reactor Building Ventilation Radiation Monitor Source Check,"
Revision 0.1
6.2SGT.101
"B SGT Filter Differential Pressure, Heater Output, and Fan Motor
Running Current," Revision 0
6.2SGT.301
"SGT Operability Test /Off-Gas Glow Monitor Functional Test,"
Revision A
6.2SGT.401
"SGT B Charcoal Filter Leak Test, Fan Capacity Test, SGT A Cooling
Flow Test and Check Valve IST," Revision 0
_ _ _
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4
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6.2SGT.501
"SGT B HEPA Filter and Component Leak Test," Revision 0.1
6.2SGT.601
"SGT B Charcoal Filter Carbon Analysis - Methyl lodine," Revision 0.1
j
6.2SJAE.301
" Steam Jet Air Ejector Flow Monitor Calibration and Functional Test,"
Revision 0
1
i
Miscellaneous Documents
ii.
Selected Liquid Radioactive Waste Batch Release Permits
4
}
Annual Operating Report Radioactive Effluents - 1994
,
l
Annual Operating Report Radioactive Effluents - 1995
!
4
i
!
Documents Reviewed During the Radiological Environmental Monitoring inspection
4
f
Oraanization Chart
4
i
General Office - Production Environment & Advanced Technology Division - January 1996
i
Procedures
Environmental Policy Department Procedures Manual
1.0
"CNS Radiological Environmental Monitoring Program," Revision 12, dated
j
i
August,1996
1.1
"CNS Environmental Air Pump Calibration and Maintenance," Revision 1,
i
dated March,1996
l
1.2
" Annual Review of Broadleaf Vegetation Sample Stations," Revision 2,
I
dated August,1996
1.3
" Annual CNS Land Use Census," Revision 1, dated August,1996
4
3
5.0
" Cooper Nuclear Station - Action Levels for Environmental Samples," Revision 1,
j
dated August,1995
i
7.2
" Transferring CNSMET Data," Revision 1, dated August,1995
l
7.3
" Logging in Strip Chart Data," Revision 1, dated August,1995
i
7.4
" Validating CNSMET Data," Revision 4, dated August,1995
7.5
" Executing All CNSMET Programs," Revision 1, dated August,1995
'
7.6
" Producing & Quality Assuring the Semi-Annual Report," Revision 2, dated
January,1996
7.7
" Producing & Quality Assuring the Annual Meteorological Report," Revision 2,
dated January,1996
7.8
" Archiving CNSMET Data," Revision 0, dtaed August,1995
8.0
" Environmental Review Program," Revision 0, dated February,1996
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i.
-8-
a
i
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Cooper Nuclear Station Operations Manual
4
Emergency Procedure 5.2.5, " Loss of Normal AC Power - USE OF EMERGENCY AC
i
POWER," Revision 28.1, dated February 23,1995
i
System Operating Procedure 2.2.90,"12.5 kV System," Revision 15, dated
-
l
March 8,1996
!
1
instrument and Control Procedure 14.3.3, " Meteorological Maintenance Procedure,"
j
Revision 4, dated April 4,1994
1
3
Quality Assurance Audit
i
Quality Assurance Audit 94-23, ASP-402, " Radiological Controls," Part 2,
October 11 through December 27,1994
Self-assessments
1996 CNS Environmental Review
Vendor Audits
NUPIC Joint Quality Assurance Audit of Teledyne Brown Engineering Environmental
Services, August 1-5,1994
'
Reoorts
Annual Operating Report Radioactive Effluents - 1994 and 1995
Annual Radiological Environmental Operating Report - 1994 and 1995
Miscellaneous Documents
"Offsite Dose Assessment Manual," Revision 6, dated March 15,1995
1996 Sample Collection Schedule
Air sampler calibration log book
USAR Volume I, Section 11.3, " Meteorology"
USAR Volume I, Section 11.6, " Environmental Meteorology"
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Training Program Description - 0703
,
l
Maintenance Work Order list for 1994,1995,1996
}
i
,
Documents Reviewed During the Solid Radioactive Waste and Transportation inspection
l
Oraanization Charts
l
Chemistry and Radwaste - June 1996
i
j
Health Physics - June 1996
i
.
Quality Assurance Audits
e
Quality Assurance Audit 94-23, ASP-402, " Radiological Controls," Part 2,
i
October 11 through December 27,1994
AOD950085," Quality Assurance Evaluation OE9534; Evaluation of the CNS Low Level
Radioactive Waste (LLRW) Storage Facility and its Operations," April 11,1995
Quality Assurance Checklist
OA/QC Checklist, " Mixed Waste Shipment 95-1P," April 10,1995
Quality Assurance Surveillances
'
OAC95068,"QA Surveillance of Mixed Waste Shipment #95-1K," February 16,1995
SC-402-03, Revision 1, " Quality Assurance Surveillance, Surveying Materials for Release
Offsite: Trash," July 13,1995
SC-402-24, Revision 0, " Quality Assurance Surveillance, Radwaste Processing and
Shipping (Using Dewatering Process)," March 11,1996
SC-402-29, Revision 0, " Transfer of Radioactive Waste to the LLRW Storage Pad,"
June 7,1995
l
Procedure
Procedure 9.5.3.1, Revision 11.1 C1, " Radioactive Shipments," July 31,1996
_
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Shiocina Documentation
Shipment 96-3A Shipping Documents,1 box (inspection equipment) to GE, Wilmington,
NC, March 28,1996
Shipment 96-4 Shipping Documents, Dewatered Resins, May 9,1996
,
Shipment 96 6A Shipping Documents,19 Boxes of protective clothing to INS,
May 29,1996
Shipment 96-6D Shipping Documents, Refuel tools to Clinton Power Station,
June 11,1996
Shipment 96-8B Shipping Documents, Sand / paint chip samples to Barringer Lab,
1
June 28,1996
Shipment 96-11B Shipping Documents, mis and HEPA unit to Oyster Creek,
August 13,1996
Shipment 96-11E Shpping Documents, Transnuclear Equipment to Quad Cities,
August 27,1996
i
Miscellaneous Documents
"Self Assessment 1996 - Radiation Protection Program," dated August 26,1996
USAR Section IX.3, " Solid Radwasto Systems"
Problem Identification Report 2-00564, dated August 8,1996
j
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