ML20138D788
| ML20138D788 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/09/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20138D770 | List: |
| References | |
| 50-298-93-04, 50-298-93-4, NUDOCS 9302230077 | |
| Download: ML20138D788 (13) | |
See also: IR 05000298/1993004
Text
-
.
.
,
APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50 298/93-04
Operating License:
Licensee:
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska
68602-0499
Facility Name:
Cooper Nuclear Station
Inspection At:
Brownville, Nebraska
Inspection Conducted: January 25-29, 1993
Inspector:
J. B. Nicholas, Ph.D., Senior Radiation Speciali t
Facilities Inspection Programs Section
Approved:
//d b,
/
O
Irlal6
urray,
e
acflities Inspection
D6te /
.
Programs Section
.
Inspection Summary
Areas Inspected:
Routine, announced inspection of the solid radioactive waste'
management and transportation of radioactive materials programs including
audits and appraisals; changes; training and qualifications of personnel;
l
solid radioactive waste management; radioactive waste classification, waste
characterization, and shipping requirements; and transportation activities.
Results:
l
Excellent audits and surveillances were performed by qualified personnel
,
(Section 1.1),
!
Quality assurance surveillances were performed on all of. the radioactive
materials and waste shipments by a radiation protection technician
assigned to the quality assurance department and trained as a quality
assurance inspector (Section 1.1).
t
IL
A supplier audit was performed on the manufacturer of the strong-tight
l
containers used to ship Type A radioactive materials and waste
l
(Section 1.1).
[
l'
4302230077 930217
L
ADOCK 05000298l
G.
PDR;
.
- . .
-
-
-
. .
-
.
. -.
.
. .
..
~
.
. _ - ..
.
.
. - . . _ -
.
+
l
e ~
..
-
,
-2-
There were no major changes in organization, personnel, facilities,
equipment, programs, and procedures (Section 2.1).
The Process Control Program was revised and approved by the Station
Operations Review Committee (Section 2.1).
Excellent accredited initial and roqualification training programs for
radwaste operators, maintenance personnel, and health physics personnel
had been implemented (Section 3.1).
The operations, maintenance, and health physics departments had well
qualified staffs to process and ship radioactive materials and waste
(Section 3.1).
The operations and health physics training instructors were well
qualified (Section 3.1).
The solid radioactive waste management program was well implemented
(Section 4.1).
Excellent radioactive waste management procedures were implement.ed
(Section 4.1).
The licensee shipped most of the onsite radioactive waste prior to the
expiration of their burial permits at the burial sites in Nevada and
Washington (Section 4.1).
'
Very good ALARA procedures were implemented by radwaste personnel
(Section 4.1).
Semiannual Radioactive Material Release Reports were timely and provided.
_
the required information in the recommended format (Section 4.1).
'
The low-level radioactive waste disposal program was conducted ir,
accordance with regulatory requirements (Section 5.1).
The licensee's quality assurance program for radioactive material.
packages was NRC approved (Section 6.1).
Excellent implementing procedures were maintained that addressed waste
classification and characterization, selection of packages, preparation
'
of packages, and delivery of the completed packages to the carrier
(Section 6.1).
Personnel responsible for the shipment and transportation of radioactive
waste and/or materials were knowledgeable of the regulatory requirements
and the burial site license conditions (Section 6.1).
Shipments of radioactive waste and/or materials met applicable
transportation requirements (Section 6.1).
-
..
-
- .-.
_ _ - _ _ _ _ _ - .
.
.
,
.
-3-
Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2
Documents Reviewed
_
- - - - -
_ - - - - _ _ _ - _ _ _ _ . _ - _ _ _ _ _ . _ - _ . _ _ _ _ _ _ _
_
_ _ _ _ _ _ .
.
.
_
1
.
-4-
DETAILS
1 AUDITS AND APPRAISALS (86750)
The inspector reviewed the quality assurance audit and surveillance programs
regarding the solid radioactive waste management and transportation of
radioactive materials programs to determine agreement with commitments in
Section X111 of the Updated Safety Analysis Report and compliance with
1.1 Discussion
The inspector reviewed the quality assurance surveillance and audit plans and
associated checklists, selected quality assurance department procedures, and
the training and qualifications of the quality assurance auditors who
performed the surveillances and audits of the radioactive materials and waste
packaging and handling and transportation activities.
Audit and surveillance
reports of quality assurance activities performed since the previous NRC
inspection of the solid radioactive waste and transportation programs in
November 1990 were reviewed for scope, thoroughness of program evaluation, and
timely followup of identified deficiencies.
The inspector reviewed the
radwaste audits performed in 1991 and 1992 in accordance with Quality
Assurance Procedure QAP-1200, " Quality Assurance Plan - Radioactive Waste
Treatment and Disposal," Revision 10, dated January 31, 1991.
The audits were
performed by qualified auditors, who were knowledgeable in the solid
radioactive wqste and transportation programs, and their applicable
requirements for nuclear power facilities.
The audit checklist adequately
covered all areas of radioactive waste materials processing, handling, and
transportation activities as required by the NRC and Department of
Transportation regulations. The audits of the solid radioactive waste and
transportation programs were of excellent quality and were satisfactory to
evaluate the licensee's performance in implementing the 'olid radioactive
waste and transportation programs.
The 1992 audit identified one minor
deficiency which was corrected before the audit was completed.
The inspector reviewed selected quality assurance surveillances performed on
radioactive materials and waste packaging, handling, storage, and on all
radioactive materials and waste t.hipments made during 1991 and 1992. The
inspector noted that the quality assurance surveillances were performed by
radiation protection personnel who were assigned to the quality assurance
department for a 12-month period. This interdepartmental training and
responsibilities were noted as a strength in both the quality assurance and
radiation protection departments.
The licensee purchases strong-tight containers for packaging radioactive
materials and waste that meet the Department of Transportation
Specification 7A Type A packages.
The licensee performed Supplier Audit
SA92-69 on December 11, 1992, of the vendor who fabricates the strong-tight
containers and determined that the vendor was supplying containers which were
manuf actured in accordance with Department of Transportation specifications.
The inspector reviewed Supplier Audit SA92-69 and noted the audit identified
i
_ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _
_ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - - _ _ _ - _ _ _ _ _ - _
. _ - .
.
.
,
I
.
-S-
.t
one deficiency.
The audit report was dated January 8, 1993; therefore, the
vendor's response to the deficiency was still pending. .The inspector verified
that the vendor was on the licensee's current qualified suppliers list.
1.2 Conclusions
Excellent audits and surveillances were performed by qualified personnel.
Quality assurance surveillances were performed on all of the radioactive
materials and waste shipments by a radiation protection technician who was.
assigned to the quality assurance department and trained as a quality
assurance auditor.
A supplier audit was performed on the manufacturer of the strong-tight
containers used to ship Type A radioactive materials and waste.
2 CHANGES (86750)
The inspector reviewed the crgani7ation, management controls, staffing, and
the assignment of solid radioactive waste management and transportation.
program responsibilities for changes and to determine agreement with the.
commitments in Section IX of the Updated Safety Analysis Report and compliance
with the requirements in Technical Specification 3/4.21.E, 6.6, and_6.8.
2.1 Discussion
The inspector.noted that th9re were no major changes since the last inspection
in organization, personnel, facilities, equipment, programs, and procedures
which had adversely affected the solid radioactive waste management'and
transportation of radioactive materials programs. The inspector reviewed the
changes made since the last inspection ~ to selected administrative, procedures,
radwaste procedures, and health physics procedures involving the~ packaging,
handling, storage, and shipment of radioactive materials and waste and found
them to provide program improvements. The Process Control Program was revised
to include a definition section, a more extensive reference section, a more
detailed description of the solidification process equipment and its
operation,.a discussion of the resin dewatering. equipment and its operation,
and the resin dewatering system's vendor process control program. The revised
Process Control Program was reviewed and approved by the Station Operations
Review Ccamittee on May 21, 1992, as required by Technical Specification 6.6.2.B..
The changes to the Process Control Program were
documented in the appropriate Semiannual Radioactive Material Release Report-
as required by Technical Specification 6.6.2.
2.2 Conclusion
There had been no major changes in organization, personnel, facilities,
equipment, programs, and procedures. The Process Control Program was revised
and approved by the Station Operations Review Committee.
t
, - -
-
e
-
--
3
- . . -
,
,.u
x.-
.-
<.~.
[.--+-
. ~
.
.
,
4
-6-
3 TRAINING AND QUALIFICATIONS (86750)
The inspector reviewed the training and qualification programs for personnel
responsible for implementing the solid radioactive waste management and
transportation of radioactive materials programs to determine agreement with
commitments in Section XIll of the Updated Safety Analysis Report and
compliance with the requirements in Technical Specification 6.1.4 and the
licensee's response to NRC Bulletin 79-19.
3.1 Discussion
The inspector reviewed the training programs for the personnel in operations,
maintenance, and health rhysics who were assigned to radioactive materials,
waste processing, and handling and transportation activities including a
review of the training facilities; health physics and operations training
instructors' qualificationr.; Training Program Description TPD-215
"Radwaste/ Auxiliary Equipment Operator"; Training Program Description TPD-408,
" ANSI H.P. Technician (Level II)"; Training Program Description TPD-416,
" Radiological Department Supervisor Personnel": and Training Program
Description TPD-420, " Contract Radwaste Shipping Assistant"; selected course
lesson plans; and individual personnel training records.
The inspector's
review of the training lesson plans found them to be very good to train
personnel in the processing and shipping of radioactive materials and waste.
It was determined that the licensee's training programs for radwaste
operators, maintenance portnnnel, anti health physics personnel were being
implemented in accordance with the nuclear training department accredited
programs.
Personnel training records indicated that the station personnel who
were assigned to perform radioactive materials and waste processing and
transportation activities had completed all of.the required initial and
requalification training.
Based on the review of the individual personnel-
training records, it was determined that operations, maintenance, and health
physics departments had adequate, well qualified staffs to perform radioactive
waste processing and transportation activities.
The inspector reviewed the
operations and health physics training instructors' experience and
qualifications and determined that they were qualified to instruct in the
radioactive waste processing and shipping technical area.
3.2 Conclusion
Excellent accredited initial and requalification training programs for
radwaste operators, maintenance personnel, and health physics personnel- had
been implemented. All required training had been completed.
The operations,
maintenance, and health physics departments had well qualified staffs to
process and ship radioactive materials and waste. The operations and health
physics instructors were well qualified.
4 SOLID RADI0 ACTIVE WASTE MANAGEMENT (86750)
The inspector reviewed the solid radioactive waste management program to-
determine agreement with commitments in Section IX of the Updated Safety
Analysis Report and compliance with requirements in Technical
Specifications 3/4.21.E and 6.5.1.F.
a.
.
-
.
.
.
.
.
-
.
.
..
.
..
. - - _ _ .
.
.
,
i .
-8-
December 31, 1991, and January 1 thr ugh June 30, 1992. These reports were
o
written in the format described in NRC Regulatory Guide 1.21 and provided a
summary of the radioactive solid waste shipped from the station for burial and
included the information required by Technical Specification 3/4.21.E.3.
During the period January 1, 1991, through June 30, 1992, the licensee had
completed 41 radioactive waste shipments by exclusive use vehicle to burial
sites in Washington, Nevada, and South Carolina.
4.2 0o_nclusions
Excellent radioactive waste management procedures were implemented.
The
licensee shipped most of the onsite radioactive waste prior to the expiration
of their burial permits at the burial sites in Nevada and Washington.
Very good ALARA procedures were implemented by radwaste personnel.
Semiannual Radioactive Material Release Reports were timely and provided the
required information in the recommended format.
5 RADIOACTIVE WASTE CLASSIFICATION, WASTE CHARACTERIZATION, AND SHIPPING
REQUIREMENTS (86750)
The inspector reviewed the licensee's program for disposal of low-level
radioactive waste including shipping manifests, waste classification, waste
form and characterization, shipment labeling, tracking of waste shipments, and
burial facility license conditions to determine compliance with the
requirements in 10 CFR 20.311, 61.55, and 61.56.
5.1 Discussion
The inspector reviewed the licensee's radioactive waste procedures for the
characterization and classification of radioactive waste for shipment and
found the procedures met the requirements of 10 CFR Part 61. The licensee and
a contract laboratory performed annual radiochemical analyses on
representative samples of the various radwaste types to meet the requirements
of 10 CFR 61.55 and 61.56.
The inspector reviewed the results of these waste
sample analyses and found the results satisfactory.
The analytical results of
the waste test samples were used to determine the isotopic composition of the
radioactive waste sources and the radioactive waste classification for
shipment.
The licensee performed isotopic analyses on each batch of
radioactive waste packaged for shipment and burial and used isotopic
correlation factors for the characterization of isotopes not directly
identified.
The inspector reviewed selected radioactive waste shipment manifests and
shipping papers that accompanied the licensee's shipments of radioactive
materials and waste.
The inspector determined that the completed manifests
and shipping papers met the requirements of 10 CFR 20.311.
I
. _ - _ - _ - _ -
.
..
- - -
.
~
-
.
.
'
'
..
.
.g.
5.2 Conclusions
The low-level radioactive waste disposal program was conducted in accordance
with the requirements of-10 CFR 20.311, 61.55, and 61.56.
6 TRANSPORTATION ACTIVITIES (86750)
The inspector reviewed the transportation program-for shipment of radioactive
materials and solid radioactive waste to determine compliance with the
requirements in 10 CFR Parts 20, 61, and 71; and 49 CFR Parts 172-189.
6.1 Discussion
6.1.1
Quality Assurance Program
The inspector verified that the licensee had received NRC Form 311,. " Quality
Assurance Program Approval," Approval 0484, Revision
3, expiration date
November 30, 1997, which provided NRC approval that the licensee's submitted
quality asr"rance program complied with 10 CFR Part 71, Subpart H.-
6.1.2
Procurement and Selection of Packages
The inspector reviewed the licensee's procurement of Department of
Transportation and NRC certified containers.
The licensee used strong-tight
containers (Department of Transportation Specification 7A Type A)- for the
shipme it of low specific activity dry radioactive waste and protective
clothino to by laundered. Of the 81 shipments made-in 1992, 39 shipments were
for burial (31 Class A and 8 Class C). These shipments included 21 shipments
of dewatered resins shipped in high integrity containers placed inside
NUPAC 14/210H casks for shipment to the burial site.
The remaining
18 shipments for burial were casks or strong-tight steel containers which
contained.primarily contaminated components taken from the spent fuel pool
during the recent cleanup project.
Seven-shipments of protective clothing
were made. The remaining radioactive materials shipments were made in
containers which contained uncompacted radioactive materials that'were being
shipped to a contractor. The licensee maintainad current documentation on the
manufacturer's design testing, maintenance, ana NRC Certificate of Compliance
for all radwaste certified containers and casks-used by the-licensee.
The
inspector verified that the licensee was on the user's list for all NRC
certified packages used.
6.' 3 Preparation of Packages for Shipment
1
The inspector verified that the licensee had procedures and checklists for the-
preparation of radioactive' waste or materials shipments. These procedures
provided for visual inspection'of the package prior. to filling the container,
instructions for closing and sealing the container, marking and labeling
requirements, and determining compliance with radiation and contamination
limits.
The licensee routinely used a checklist to assure that procedures
were followed and that packages were prepared properly for shipment in:
"
accordance with NRC, Department of Transportation, state, and burial site
requirements. Discussions with individuals involved in the preparation of
3
. . . - .
-
,
.
r
_ _ _ _
_
___
_ _ _ _ _ _ - _ _ _
._
.
,
,
..
-10-
-packages of radioactive materials or waste for shipment indicated that they
possessed a working knowledge of the licensee's procedures and NRC and
Department of Transportation regulations pertaining to the preparation of
packages for shipment.
6.1.4 Delivery of Completed Packages to Carriers
The inspector verified that the licensee's procedures included the required
NRC and Department of Transportation regulations.
A review of selected
records and shipping papers for radioactive waste shipments indicated that the
-licensee had prepared appropriate manifests and shipping' papers-in accordance
with approved-procedures and that-the shipping papers included the necessary'
,
information to comply with regulatory requirements.
The licensee.used only
exclusive use carriers for all radioactive waste shipments and assured that
-the following items were in accordance with NRC and Department of
.
Transportation regulations and station procedures:
radiation levels were
'
within required limits, transport vehicles were placarded properly, surface
contamination on packages did not exceed requirement levels, and blocks and/or
braces were in place to prevent damage or shifting of the losd during transit.
6.1.5 Records, Reports, and Notifications
l
L
The inspector reviewed selected records of eight radioactive waste shipments
made by the licensee during 1992.
The shipments were adequately documented to
meet NRC and Department of Transportation regulations.
The licensee
maintained records of all radioactive waste and/or materials shipments'as
,
!
required.
Thp records included all shipping documentation, radiation surveys,
'
and required notification information.
6.2 Conclusions
l
l
l_
The licensee's quality assurance program for radioactive material packages was-
NRC approved.
Excellent implementing procedures that addressed waste classification and
characterization, selection of packages, preparation of oackages,and delivery
of the completed packages to the carrier were mcintained.
_
'
Personnel responsible for the shipment and transportation of radioactive waste
and/or materials were knowledgeable of the regulatory requirements and the
burial site license conditions.
Shipments of radioactive waste and/or materials met- applicable transportation-
requirements,
h
l
,
. . -
- .
.
~. -
-
,
-.
. _ - _ _ _ _ _ _ _ _ _
'
.
.
ATTACHMENT 1
1 PERSONS CONTACTED
1.1
Licensee Personnel
- J. M. Meacham, Site Manager
S. N. Bahr, Radioactive Material Shipping Technician
- R. L. Beilke, Radiological Support Supervisor
- L. E. Bray, Regulatory Compliance Specialist
-
- G. D. Bray, Auxiliary Radwaste/ Equipment Supervisor
- S. L. Bray, Operations Quality Assurance Supervisor
- R. Brungardt, Operations Manager
T. J. Chard, Health Physicist
- M. A. Dean, Nuclear Licensing and Safety Supervisor
- R. L. Gardner, Plant Manager
- M. A. Gillan, Technical Training Supervisor
- H. A. Jantzen. Instruments and Controls Supervisor
J. W. Jones, Instruments and Controls Technician
- J. H. Kutler, Senior Chemistry and Health Physics Specialist
R. L. Mason, Instruments and Controls Technician
C. E. McElfresh, Auxiliary Radwaste/ Equipment Operator
D. P. Oshlo, ALARA Coordinator
,
C. H. Putnam, Jr., Quality Assurance Specialist
E. M. Rotkvic, Nuclear Instructor / Health Physics
- J. V. Sayer, Radiological Manager
G. A. Schmielau, Maintenance Planner
1.2 NRC Personnel
- R. A. Kopriva, Senior Resident Inspector
- W. C. Walker, Resident Inspector
- Indicates those present at the exit meeting on January 29, 1993.
2 EXIT MEETING
An exit meeting was conducted on January 29, 1993.
During this meeting, the
inspector reviewed the scope and findings of the report. The licensee did not
identify as proprietary any information provided to, or reviewed by, the
inspector.
.
,
.
- Mf
Ju
a*-
m
T-
"
s
-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .
.
.
,
.
ATTACHMENT 2
DOCUMENTS REVIEWED
Title
Revision
Date
1.
Administrative Procedures
0.2, Station Organization and Responsibility
10
02/13/92
0.17, Selection and Training of Station
'14
10/29/92
Personnel
2.
Radwaste Procedures
2.5.1.2, Radwaste Low Condur.tivity Liquid
16
06/11/92
Waste Condensate Phase Separator fluid
Transfer
2.5.1.3, Radwaste Low Conductivity Liquid
11
08/08/91
Waste Spent Resin Tank Fluid Transfer
2.5.1.6, Radwaste Low Conductivity liquid
21
02/13/92
Wasta Saicple Tank fluid Transfer
2.5.1.7, Reactor Water Cleanup Phase Separator
14
10/31/91
Tank Transfer
2.5.2.l!RadwasteHighConductivityLiquid
11
06/11/92
Waste and Waste Sludge Tank Fluid Transfer
2.5.4.1, Solid Wet Waste Packaging, Storage,
16
07/25/91
and Transfer System
2.5.4.2, Solid Wet Waste Drum filling
6
08/06/92
.
2.5.4.3, Radwaste Drum Mixer Operation
8
07/16/92-
2.5.4.4, NUPAC Dewatering System Operating
2
10/31/91
Procedure
3.
Training lesson Plans
OTH010-01-01, Radwaste Packaging and Handling
4
10/29/92
OTH010-02-01, Verification of Solidification
3
04/16/91
OTH016-01-01, Radiological Professional Development 2
03/01/91
SKL018-02-47, Perform Receipt of Source /Non-Source 3
03/05/92
Radioactive Material
SKL018-04-51, Survey Incoming Transport Vehicle
3
01/30/92
..
- .. .
.
.
-.
.
.
,
4
l
-2-
3.
(continued)
SKLOl8-04-52, Survey Outgoing Transport Vehicle
3
01/31/92
SKL018-04-53, Supervise loading Van Shipment
3
03/05/92
SKL018-04-54, Supervise loading Cask Shipment
3
02/10/92
SKL018-04-55, Prepare Records for the Shipment
3
02/10/92
of Radioactive Materials
SKL018-04-57, Survey Waste Materials in
3
03/05/92
Preparation for Packaging
SKLO39-01-01, NUPAC Dewatering System
0
03/18/91
4.
Maintenance Procedure
7.9.2, Filling Radwaste Containers With Waste
15
02/28/91
5.
Health Physics Procedures
9.5.1, Receipt of Radioactive Materials
7
12/13/90
9.5.1.1, Survey of New Nuclear fuel Shipments
0
04/25/91
9.5.3.1, Radioactive Waste Shipmant for Burial
B
11/21/91
9.5.3.2, Radioactive Material Shipment
6
11/21/91
(Non-Burial)
9.5.3.3, Condensate Cleanup Waste Resins, Spent
9
12/17/92
Resins, and Waste Sludge Classification and
Listing
9.5.3.4, Reactor Water Cleanup Waste Resins
8
12/17/92
Classification and Listing
9.5.3.5, Dry Radioactive Waste Classification
8
02/28/91
and Listing
9.5.3.6, Completion of Waste Manifest
5
06/04/92
Instructions (US Ecology)
9.5.3.7, Campletion of Chem-Nuclear's Waste
0
12/17/92
Manifest Instructions
9.5.3.9, Solidifying and Packaging Contaminated
3
05/13/91
Liquids for Burial
9.5.3.10, Waste Stream Sampling
3
12/17/91
- - _ _ _
_ _ _ _ _ _ _ _ -
-
__ _ _ _ _ _ _ _ _ _
.
.
-3-
6.
Quality Assurance Audits
Quality Assurance Audit Report 91-10, QAP-1200
"Radwaste," conducted
June 5, 1991 through July 31, 1991
Quality Assurance Audit Report 92-11, QAP-1200
"Radwaste," conducted
May 26, 1992 through October 2, 1992
Quality Assurance Suppliers Audit SA92-69, Plymouth Manuf acturing, Inc.,
conducted December 11, 1992
7.
Semiannual Radioactive Material Release Reports
January 1 through June 30, 1991
July 1 through December 31, 1991
January 1 through June 30, 1992
.
-
-.
"
- - - - - . _ - . _ - _ _ - . _ _ _ _ _ _ _