IR 05000482/1985043
| ML20141K476 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/17/1985 |
| From: | Murray B, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141K463 | List: |
| References | |
| 50-482-85-43, NUDOCS 8601220540 | |
| Download: ML20141K476 (8) | |
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APPENDIX B U.S. NUCLEAR PEGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-482/85-43 Lict:nse: NPF-42 Docket: 50-482 Licensee:
Kansas Gas and Electric Company (KG&E)
P. O. Box 208 Wichita, Kansas ~ 67201 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: WCGS Site, Burlington, Kansas Inspection Conducted: December 2-6, 1985 Inspectar:
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D."Bi Spitzberg, Raqiation Specialist Date
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Facilities Radiological Protection Section
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Approyed:
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/N//7[8f laine Murray, Chief, Facilities Radiological Date '
l Protection Secti6n Inspection Summary t
Inspection Conducted December 2-6,1985 (Report STN 50-482/85-43)
i Areas Inspected: Routine, unannounced inspection of.the licensee's radiological environmental monitoring program (REMP) including: organization and management controls; qualifications and training; radiological environmental monitoring program; meteorological monitoring program; quality contrcl of radiological analytical measurements; quality assurance (QA) program; contractor activities; i
I and reportable occurrences.
In addition, an allegation concerning radioactive l
releases to.the cooling lake was reviewed. The inspection involved 37 inspector-hours onsite and 7 inspector-hours offsite by 1 NRC inspector.
Results: Within the areas inspected, no violations were identified. One-deviation was identified in the area of radiological environmental monitoring program (see paragraph 8).
The allegation was not substantiated (see paragraph 13).
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-2-DETAILS 1.
Persons Contacted
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KG&E
- R. Hagan, Man'ager, Nuclear Services
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- C. Swartzendruber, Manager, Radiological Services O. Maynard, Manager, Licensing
- W. Rudolph II, Manager, QA
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- R. Potter, QA (Supplier)
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- G. Wedd, Supervisor, Environmental Management
- R. Logsdon, Site Chemist R. Stambaugh, Supervisor, QA Audits J. Gilmore, Senior Reactor Operator
- K. Peterson, Lead Engineer, Licensing
- V. King, Senior Engineer, Radiological Services M. Shafer, Engineering Specialist III
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B. Vinie, Environmental Biologist D. Williamson, Environmental Biologist
D. Haines, Environmental Biologist
- M. Hall, Licensing Engineer-i
- L. Loney, Engineering Specialist i
i G. Atwood, Licensing Engineer L. Herhold, Training Coordinator D. McFeeders, Engineering Specialist III, Instruments and Controls (I&C)
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M. Hawk, Lead Computer Engineer, I&C
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- C. Hock, QA Technician
- B. Loveless, Environmental Technician II
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Others
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- J. Cummins, NRC Senior Resident Inspector o
- B. Bartlett, NRC Resident Inspector
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- Denotes those present during the exit interview on December 6, 1985.
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- Denotes those present during the pre-exit interview at WCGS on December 5, 1985..
2.
Licensee Action on Previously Identified Open Items (Closed) Open Item (482/8411-01):
System Reliability of the Radiological s,
Release Information System (RRIS) for Providing Meteorological Data - This, item was discussed in NRC Inspection Report 482/84-11, and involved the RRIS's capability to provide reliable meteorological data to the control room and other areas specified in Regulatory Guide 1.23. At the time of
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r-3-the 84-11 inspection, the system was not fully operational in that the data link which was to transmit the meteorological data had not completed installation.
In reviewing this item, the NRC inspector determined that the RRIS was fully operational with data terminals in the control room, technical support center, emergency offsite facility, and main computer center. A compilation of system availability for Technical Specification (TS) parameters (wind speed, wind direction, air temperature dif ferential)
was reviewed and found to be adequate. A demonstration of the system's capabilities was observed in the control room and logs of required TS parameter channel checks were noted.
The NRC inspector determined that the licensee's actions were adequate to resolve the concerns in this area.
This item is considered closed.
3.
Inspector Observations The following are observations the NRC inspector discussed with the licensee. These observations are neither violations nor unresolved items.
These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that these items would be reviewed.
Certain required data for the Semiannual Radiological Effluent
Release Report was not available at the time the report was issued on August 30, 1985.
This data, for strontium-89 and 90 in liquid and gaseous effluents, was noted in the report as not yet available from the offsite contractor laboratory, a period of some 60 days from the end of the reporting period to the date of the report submittal (see paragraph 10).
The licensee had not developed a systematic approach for comparing
the results of sampling from their own program with those of the State and NRC programs for radiological environmental analyses (see paragraph 11).
The auditor that performed the 1985 QA audit of the environmental
monitoring program did not have technical expertise in environmental activities (see paragraph 6).
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4.
Organization and Management The NRC inspector reviewed the licensee's organizational structure and managen.ent with respect to the radiological environmental monitoring programs (REMP) to determine if they met the requirements of the TS, Section 6, Final Safety Analysis Report (FSAR), Environmental Report (ER-OLS), and administrative procedures. The NRC inspector determined that the environmental program has been administered from the KG&E Corporate office by the Manager of Nuclear Services. The NRC inspector
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-4-determined that the review and support of the program at the corporate level has been the responsibility of the radiological projects group under the direction of the Manager, Radiological Services.
The WCGS site personnel involved in implementing the environmental program have reported to a separate line management structure under~the direction of the Manager of Licensing.
The NRC inspector reviewed the overall program staffing anb found that all personnel supporting the environmental program were KG&E_ employees. The staff turnover since the previous inspection was.found to be low and a sufficient. number of personnel appeared to be in place to implement the program. Position descriptions and responsibilities for management and technical staff members were reviewed.
'No violations or deviations were identified.
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5.
Training and Qualifications
The NRC inspector reviewed the environmental monitoring program's staff training and qualifications to determine compliance with Sections 6.3 and 6.4 of the TS, commitments 3.ade in the FSAR, and with administrative procedures.
The NRC inspector determined that the corporate environmental program's staff members followed a separate training regimen than the onsite plant staff personnel in that specific technical training and development was undertaken through programs offered within the group or. j through outside training. The NRC inspector reviewed the operation procedures in this area, KP-LE208.and KPC 2050, and determined that since the procedures went_ into effect, all personnel joining the staff had been trained. Documentation was on file (Form KSF-C30) showing that staff members had read all procedures applicable' to their job functions.
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reviewing the qualifications of the supervisory personnel, it was noted that they appeared to meet the~ minimum qualifications specified in 'their-
job descriptions.
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No violations or deviations were identified.
6.
Audits The NRC inspector examined the licensee's audit' program to determine.if-it had been implemented in the area of radiological 'environmdntal monitoring in accordance with Section 6.5.2.8 of the TS, ANSI N45.2.23-1978,'and the
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Site QA Manual.
It was determined that since the previous inspection, the requirement for' annual audits of the environmental monitoring programs had been met with the issuance of audit report TE:50140-K055 on June 25, 1985.
-The NRC inspector reviewed the' scope and findings of the audit and found it to be comprehensive and adequately documented. _The. audit had been performed by a single individual-who, it was noted, had been certified. in accordance with ANSI N45.2.23-1978,- but whose technical training and
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~No violations or deviations were identified.
7.
Program Changes The NRC inspector discussed with cognizant licensee personnel changes in the Offsite Dose. Calculation Manual (00CM) including the environmental monitoring program, and the Process Control Program (PCP) which are required by TS 6.9.17 to be reported in the Semiannual Effluent Release Report..For the period of January 1 through June 30, 1985, no changes in these programs were reported.
It was noted that revisions in the ODCM were made on July 8,1985, changing certain dose conversion tables, and that a change ~to the PCP was approved with Revision 3, dated July 19, 198S, adding a backup radwaste processing service.
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No violations or deviations were identified.
8. " Radiological Environmental Monitoring Program
The NRC inspector examined aspects of the REMP to determine if it had been
- conducted in accordance with Section 3/4.12 of the TS, Section 6.1.5 of
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the Environmental Report (0LS), the ODCM, and environmental assessment procedures. All environmental samples obtained for the REMP have~been analyzed by an offsite laboratory under contract to KG&E. By. reviewing the results of the sampling program obtained since the previous inspection, it was' determined that the program had been conducted according to-requirements for sample type, sample location, sampling frequency, and type of analysis.
It was noted during this review, however, that four-broadleaf vegetable samples analyzed.in 1984 did not meet the lower limit of detection _(LLD) valce specified in Table 6.1-18 of the ER (OLS) for iodine-131. This LLD value of 60 pCi/kg corresponds to the TS LLD in
'Section 4.12.1, Table 4.12-1.
Since the' samples in question were analyzed prior to issuance of the WCGS operating license, this finding was identified as a deviation from commitments made in the Environmental Report (482/8543-01).
On December 3,1985, the NRC inspector accompanied licensee-personnel on their. routine environmental sample collection program for air particulate
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and iodine, and drinking water..In addition, several environmental thermoluminescent dosimeter, milk, and vegetation sample locations were 1'nspected. There were no problems noted withithe field sampling stations or the licensee's sample collection, marking, and shipping preparation techniques ~.
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-6-The NRC inspector reviewed records of air sampler calibrations and maintenance and found that this function had been performed according to procedure KP-RE209.
No violations were identified.
9.
Meteorological Monitoring Program The NRC inspector reviewed the licensee's program for the acquisition of meteorological data to determine compliance with Section 3.3.3.4 of the TS, FSAR, station procedures, NUREG-0737, and recommendations of Regulatory Guides 1.23 and 1.97.
As mentioned in paragraph 2 of this report, the operation and reliability of the meteorological data transmission link of the RRIS was verified.
This review served to close open item 482/8411-01, created due to concerns over reliability of the meteorological data link.
The NRC inspector observed the operation of the RRIS and reviewed records of channel checks performed each shift by a control room operator. Also
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reviewed were records showing that the meteorological instruments referenced in the TS had been calibrated at least at the required 6-month frequency, according to procedures STS IC-890A, B, and C.
An inspection was made of the meteorological instrument tower to verify that the data recorders located in a structure at the base of the tower were operational and could be used to acquire meteorological data in the event of RRIS failure.
No violations or deviations were identified.
10. Reports, Manuals, and Procedures In the area of radiological environmental monitoring, the NRC inspector reviewed licensee's reports and procedures issued or revised since the previous inspection to determine compliance with Sections 3/4.12.2, 6.8.1, and 6.9.1.7 of the TS and ANSI 18.7-1976.
The first semiannual effluent release report dated August 30, 1985, covering the period from January 1, 1985, through June 30, 1985, was reviewed and was found to meet the requirements of TS 6.9.1.7.
However, it was noted by the licensee in the report that data for strontium-89 and 90 in liquid and gaseous effluents was not yet available from the contractor laboratory at-the time the report was issued.
The NRC inspector recommended to licensee representatives that efforts be made to ensure that all required data is available within the 60 days prior to issuing these reports in the future.
The NRC inspector reviewed copies of the latest revisions of the ODCM, radiological assessment procedures, and the 1985 Population / Land Use Survey requireo by TS 3/4.12.2, and found them to be adequate.
No violations or deviations were identified.
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-7-11. Quality Control of Radiological Analytical Measurements and Contractor Activities The NRC inspector reviewed the methods employed by the licensee to ensure
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the quality of the results of radiological environmental monitoring to determine if these methods met the' requirements of Section 3/4.12.3 of the TS, the'0DCM, environmental assessment procedures, and the recommendations of Regulatory Guide 4.15.
It was observed that internal controls had recently been upgraded by developing a computer program to identify deficient data. Records were also reviewed of environmental noncompliance reports completed according to procedure KP-RE202, which have served as. n a
internal control for the monitoring program.
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The NRC inspector did bring to the attention of the licensee that additional confidence in the monitoring program quality could be achieved by developing a method of comparing the results of monitoring accomplished by the licensee, State of Kansas, and NRC at colocated sample sites.
The NRC inspector reviewed the contractor laboratory's quality control manual IWL-0032-361, with letter dated July 18, 1985, which describes the EPA sponsored laboratory cross check program and the results achieved during the past year. This document appeared to meet-the requirements of TS 3/4.12.3 for the interlaboratory comparison program as well as the recommendations of Regulatory Guide 4.15.
The annual audit of the.
contractor laboratory TE 59451-K007, dated October 25, 1985, which was performed by the corporate QA staff (supplier), was reviewed.
No violations or deviations were identified.
12. Reportable Occurrences The NRC inspector determined that the licensee experienced no reportable occurrences or events in the area of radiological environmental monitoring dating back to the previous inspection.
No violations or deviations were identified.
13. Allegation Review The NRC inspector reviewed an allegation described in allegation case-
. numbers 4-85-A-094 and 4-85-A-109, which stated that the licensee dumped radioactive liquid into the cooling lake in order.to avoid ehutdown. The dates involved with the allegations'were August 10,1985(4-85-A-094),and
"on or about August 4, 1985" (4-85-A-109). A complete review was made of all Radioactive Liquid Release. Permits-(Form ADM-04-023) on file for the period August 3-11, 1985. -With the exception of two permits, all releases-had been. routine releases from the two primary monitor tanks and had
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-8-P consisted principally of tritium, with only trace quantities of other isotopes. The release volumes had been sampled, analyzed,' monitored, and documented according to procedures ACM-04-023, CHM 03-140, CHM 01-001, CHM 01-002, CHM 01-100, and CHM 03-021. The concentrations of isotopes released were well below the allowable TS concentrations and the maximum permissible concentrations specified in 10 CFR Part 20.
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The remaining two permits concerned a release begun on August 10, 1985, and continued through August 16, 1985, associated with a special test using radioactive sodium-24 (Na-24) introduced into the secondary [ steam generator (SG)] coolant for the purpose of monitoring moisture carryover in the steam. These release permits were discussed with the supervisor of site chemistry. A nominal 900 mci of Na-24 (Th = 15h) was used for the test with the preferred blowdown (discharge) going to the condenser. The backup blowdown pathway was to the lake. During the test, a condensate demineralizer filter plugged such that it deprived the operators from blowing downoto the condenser. A decision was made to proceed blowing down to the lake-(normal rate about 360 gpm for four SGs).
Radioactive Liquid Release Permits 85141 and 85142, dated August 9, 1985, had been prepared and approved according to the previously referenced _ procedures to cover either discharge pathway. The NRC inspector examined the radiochemistry sample results dated August 10, 1985 (BMST-85040), which showed the Na-24 concentration to be 4.043E-4 uCi/ml in the 240,462 gallon volume to be discharged. This volume was discharged during the 6 day
period to the circulating water system (CWS) with release to the lake using three CWS pumps of 175,000 gpm capacity each. ~Thus, the release
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concentration for Na-24 at_the point of release to.the lake.was substantially below the regulatory limit of 2E-4 uCi/ml. The NRC inspector also reviewed data covering the period of the release from the process radiation monitors for the SG blowdown effluent (BLM526) and the turbine building drains (LEL596) and determined that the maximum concentrations s
recorded were on August 10, 1985, and corresponded to 7.28E-5 uCi/ml and 5.23E-6 uCi/ml, respectively. Based upon these findings the NRC inspector concluded that no radioactive liquid releases made to the cooling. lake during the period August 3-11, 1985, violated TS or 10 CFR Part 20 requirements.
No violations or deviations were identified.
14. Exit Briefing The NRC inspector held a meeting with the WCGS site personnel and NRC
. resident inspectors identified in paragraph 1 on December 5,1985, to discuss the findings to that point of_ the inspection. An exit briefing was held at the-KG&E corporate office on December 6, 1985' with_the staff
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members noted in paragraph 1 to summarize the-findings of the inspection.
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The licensee acknowledged the NRC inspector's comments and observations.
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