IR 05000482/1986031

Insp Rept 50-482/86-31 on 861117-21.No Violations or Deviations Noted.Major Areas Inspected:Licensee Liquid & Gaseous Radwaste Mgt Programs,Including Organization & Mgt Controls & Training & Qualifications

ML20207N075
Person / Time
Site:	Wolf Creek
Issue date:	12/30/1986
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207N058	List: IR 05000482/1986031 ML20207N056
References
50-482-86-31, NUDOCS 8701130434
Download: ML20207N075 (8)

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APPENDIX U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report: STN 50-482/86-31- License: NPF-42 Docket: STN 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: November 17-21, 1986 Inspector: .- d / 86 u--df B. Nicholas, Radiation Specialist Date Facilities Radiological Protection Section

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Approved: o - ,I MU /P/So 64 Bf Murray, Chief, Facilities Radiological Date Protection Section Inspection Summary Inspection Conducted November 17-21, 1986 (Report STN 50-482/86-31)

Areas Inspected: Routine, unannounced inspection of the licensee's liquid and gaseous radioactive waste management programs, including organization and management controls, training and qualifications, radioactive waste effluent releases, records and reports of radioactive effluents, radioactive waste effluent release procedures, effluent monitoring instrumentation, air cleaning systems, reactor coolant and secondary water quality, quality control of analytical measurements, and quality assurance (QA) progra .Results: Within the areas inspected, no violations or deviations were identifie Dk 4 4 870107 -

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-2-DETAILS

' Persons Contacted t

KG&E

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• F. T. Rhodes, Plant Manager

• J. A. Bailey, Interium Site Director R. H. Belote, Manager, Safety Engineering

• G. D. Boyer, Deputy Plant Manager B. W. Cope, Radwaste Coordinator, Chemistry W. K. Drogemuller, Reactor Operator

• Gaul, Radwaste Engineer

• C M. Estes,. Superintendent, Operations

• A. A. Freitag, Manager, Nuclear Plant Engineering S. A. Henry, Primary Chemistry Supervisor

• C. J. Hoch, QA Technician

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• J. A. Ives, Site Health Physicist

• B. M. Kinney, Superintendent, Technical Support

• W. M. Lindsay, Supervisor, Quality Systems

• R. L. Logsdon, Site Chemist

• M. H. Megehee, Compliance Engineering K. L. Miller, Instrument and Control Technician T..S. Morrill, Chemistry Supervisor

• M. M. Nichols, Superintendent, Plant Support

• C. L. Palmer, Radwaste Chemistry Supervisor

• C. E. Parry, Superintendent, Quality Systems Engineering

• G. J. Pendergrass, Licensing Engineer

• W. D. Pyle, Radiochemistry Counting Room Coordinator K. R. Peterson, Licensing Lead Engineer

• R. C. Richardson, Radwaste Coordinator, Operations W. J. Rudolph II, Manager, QA R. M. Stambaugh, Supervisor, QA Audits

• M. Thrall, Senior Engineering Specialist M. G. Williams, Superintendent of Regulatory, Quality, and Administration

• J. A. Zell, Manager, Nuclear Training J. D. Ziesenis, Secondary Chemistry Supervisor Others

• B. L. Bartlett, NRC Resident Inspector, Wolf Creek

• J. E. Cummins, Senior NRC Resident Inspector, Wolf Creek G. R. Bruschi, Surveillance Coordinator Consultant, Volt Information Services, In *R. P. Mullikin, NRC Project Inspector

• G. A. Pick, NRC Project Inspector

• Denotes those present during the exit briefing on November 21, 198 , _ ,

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-3- Inspector Observations The following are observations the NRC inspector discussed with the licensee during the inspection and at the exit briefing on November 21, 1986. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee stated these items would be reviewed, Radioactive Effluent Composite Sample Results - The analytical results from radwaste composite samples are not recorded or tracked as part of a surveillance test procedure (see paragraph 5). Offsite Dose Data in Effluent Reports - The licensee had not included a correlation and interpretation of offsite dose results against Technical Specification (TS) limits (see paragraph 6). Effluent Isolation Valve Testing - The licensee does not test radiation effluent monitor isolation capability before each radioactive effluent release (see paragraph 7). Organization and Management Controls The NRC inspector reviewed the licensee's onsite organization and staffing regarding the radioactive waste effluent program (RWEP) to determine agreement with commitments in Chapter 13 in the Final Safety Analysis Report (FSAR) and the requirements in Section 6.2 in the T The NRC inspector verified that the organizational structures of the WCGS radwaste operations section and chemistry / radiochemistry section (C/RS)

were as defined in the FSAR and T Since the previous NRC radwaste inspection in August 1985, a new position of radwaste coordinator-operations had been established and filled, transferring the responsibility of radwaste effluents to the WCGS operations sectio The WCGS management control procedures and position descriptions were reviewed for assignment of responsibilities for the management and implementation of the WCGS RWE The NRC inspector verified that the administrative control responsibilities specified in WCGS procedures were being implemente The NRC inspector reviewed the staffing of the radwaste operations section and C/RS and determined that both sections were fully staffed. Since the previous NRC radwaste inspection in August 1985, the licensee's C/RS which manages the RWEP had replaced two chemistry technicians and the radwaste operations section had experienced no personnel turnove No violations or deviations were identifie ,

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-4- Training and Qualifications The NRC inspector reviewed the training and qualifications of the C/RS staff and nonlicensed radwaste operators responsible for the RWEP to determine agreement with commitments in Chapter 13 in the FSAR and the requirements in Sections 6.3 and 6.4 in the T The NRC inspector reviewed the education and experience backgrounds of the present C/RS staff responsible for the RWEP and verified that they met the required qualifications specified in the FSAR and TS.

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The NRC inspector reviewed the training program for C/RS personnel and nonlicensed radwaste operators, including a review of training procedures, personnel training records, and qualification cards. The NRC inspector found that the licensee's training program was being implemented in accordance with WCGS procedure The NRC inspector reviewed individual staff training records and qualification cards for selected C/RS personnel and nonlicensed radwaste operators responsible for performing RWEP activities. The NRC inspector verified that the C/RS technicians and nonlicensed operators responsible for performing RWEP activities had completed the required training on Radiological Effluent Technical Specifications (RETS) and radwaste system No violations or deviations were identifie . Radioactive Waste Effluent Releases The NRC inspector reviewed the licensee's liquid and gaseous radwaste processing systems and procedures and records associated with liquid and gaseous release permits to determine agreement with commitments in Chapter 11 in the FCAR and requirements in Sections 3/4.11 and 6.15.1 in the TS, offsite dose calculation manual (0DCM), and the design objectives of 10 CFR Part 50, Appendix Liquid The NRC inspector reviewed a representative member of liquid release permits for the period January through October 1986. It was determined that processing, sampling and analysis, and releases were conducted in accordance with WCGS procedures. Quantities of radioactive nuclides released in the liquid effluents were within the limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within TS limit The NRC inspector verified that the licensee was performing, by use of a contract laboratory, the TS requirements for gross alpha analysis, sa Sr and 90 Sr analyses, and 55 Fe analysis on composites of batch liquid release The required analyses were being performed as required and the analytical results were being recorded on the primary chemistry daily log sheets when received from the contract laborator . ~

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-5-However, the NRC inspector observed'that these analyses and result records'were not being logged nor tracked as part of a specific surveillance test procedure. As a result, the analytical analyses were not being updated in the liquid release data computer file This observation was discussed with the licensee during the inspection and at the exit briefing on November 21, 1986. The licensee stated that the NRC inspector's observation would be reviewe The NRC inspector determined that the only change made to the operation of the liquid radwaste system since the previous NRC inspection in August 1985 was the routine use'of the secondary radwaste evaporator for processing liquid radwaste and the routine discharge of liquid radwaste from the secondary monitor tank Gaseous The NRC inspector reviewed selected gaseous waste release permits, which included unit vent and radwaste building exhaust stack

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continuous releases and waste gas decay tank and containment batch releases for the period January through October 1986. It was determined that gaseous waste releases were performed according to procedures and the quantities of gaseous radioactive nuclides released were within the limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within the TS limits. The NRC inspector made a similar observation with the gaseous effluent composite sample analyses results for gross alpha and 89Sr and 90Sr as discussed in the previous paragraph concerning liquid radioactive waste effluents. The NRC inspector determined that no design changes had been made to the gaseous radwaste management system since the previous NRC inspection in August 198 The NRC inspector reviewed selected operations and chemistry daily log sheets for the period January through October 1986 to determine

. compliance with TS hydrogen and oxygen controls and maximum noble gas

,. curie content in the waste gas holdup system. The licensee's analysis frequency and results met TS requirement No violations or deviations were identifie . Records and Reports of Radioactive Effluents The NRC inspector reviewed the licensee's records and reports concerning radwaste systems and effluent releases to determine compliance with the requirements of 10 CFR Part 50.36(a)(2) and Sections 6.9.1.7 and 6.14 in the T The NRC inspector reviewed the semiannual reports for the periods May 22 through June 30,1985, July 1 through December 31, 1985, and January 1 through June 30, 1986. These reports were written in the format described in NRC Regulatory Guide 1.21 and contained the information required by T ._. _ _ ._ _ _ _ _ _ _ _ _ _ _ _ . _-

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-6-The NRC inspector reviewed the implementation of RETS to determine agreement with the TS. It was determined that all required information was available and reported to verify compliance with TS requirements.

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However, the NRC inspector observed that the licensee had not provided a correlation and interpretation of offsite dose results against TS limit The NRC inspector's observation involving format and explanation of effluent release offsite doses as they relate to TS requirements was discussed with the licensee. The licensee recognized the lack of technical explanation and summary of offsite dose data in the semiannual report The licensee stated they would review the present format used in the semiannual reports and implement modifications where necessary to ensure that the technical data and information is presented in a logical format which readily demonstrates compliance with T No violations or deviations were identifie . Radioactive Waste Effluent Release Procedures The NRC inspector reviewed the licensee's effluent release procedures to determine compliance with the requirements in Section 3/4.11 in the T The NRC inspector reviewed current approved revisions of WCGS procedures governing the release of liquid and gaseous radioactive waste. -The NRC inspector noted that the licensee's effluent release procedures do not require the testing of effluent isolation valves before each release by initiating an isolation signal through the alarm / trip setpoint of the controlling radiation monito This trip or isolation testing is performed quarterly during the analog channel operational test on the radioactive liquid and gaseous effluent monitors which provide alarms and automatic termination of radioactive effluent releases. This observation was discussed with the licensee, who intends to evaluate the frequency of testing to demonstrate that automatic isolation of an effluent discharge pathway occurs if the radiation monitors measure radiation levels above the alarm / trip setpoin No violations or deviations were identifie . Radioactive Waste Effluent Monitoring Instrumentation i

The NRC inspector reviewed the licensee's effluent monitoring instrumentation and procedures used in calibration of the effluent monitors which control effluent releases to determine compliance with the requirements in Sections 3.3.3.10 and 3.3.3.11 in the T The NRC inspector reviewed calibration and alarm / trip setpoint procedures and records for the radioactive liquid effluent monitor The NRC inspector verified that the primary calibrations of the liquid effluent monitors were performed with liquid radioactive standards in the same configuration as the actual samples being measured in the effluent streams. The radioactive standards used were traceable to the National Bureau of Standards and were of various activity levels to cover the full

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.c ci range offeach monitor.q The calibrations and setpoint determination were-verified to have been performed.according to approved procedures. The NRC

' inspector visually _ inspected the operation of the_ liquid and gaseous effluent monitors and determined that all.radwaste effluent radiation monitors were operating =at the time of the inspectio No viol'ations or deviations were ' identified Air Cleaning Systems The NRC inspector reviewed the licensee's surveillance tests for air cleaning systems containing high efficiency particulate air (HEPA) filters and activated charcoal adsorbers to determine agreement with commitments in Chapter 9.4 in the FSAR and the requirement in Sections'3/4.7.6 and 3/4.7.7 in the T The NRC inspector. verified.that the licensee's procedures and surveillance tests provided for the required periodic functional checking of system

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components, testing of HEPA. filters and charcoal adsorbers system

+ operating hours. The~ licensee had written surveillance tests for the control room emergency ventilation sys_ tem and emergency exhaust system and scheduled their performance in accordance with TS requirement No violations or deviations were identifie '

1 Reactor Coolant and Secondary Water Quality L -

The NRC. inspector reviewed the licensee's program for monitoring and controlling the reactor coolant.and secondary water quality to determine agreement with commitments in Chapters 5, 9, and 11 in the FSAR and the requirements in~Section 3/4.'4.7 and 3/4.4.8 in the T The NRC inspector reviewed selected reactor coolant and secondary water chenistry analysis log sheets for the period January through October 198 The records indicated that all required sampling and analyses were performed at the frequencies required by the TS and that the analyses results met TS requirement ,

- No violations or deviations were identified.-

'1 Quality Control of Analytical Measurements The NRC-inspector inspected the radwaste laboratory and radiochemistry counting _ room and reviewed the licensee's program for calibration and quality control of. chemical and radiochemical analytical measurements to determine compliance with the requirements in Section 6.8 in the T . The NRC inspector inspected the licensee's radwaste laboratory and radiochemistry counting room instrument calibration and quality control

- procedures, counting instrument calibration data and performance check data, and other documentation of instrument performance during the NRC [

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-8-inspection of chemistry / radiochemistry activities conducted September 29 through October 3, 1986. The satisfactory results of that inspection were reported in NRC Inspection Report 50-482/86-2 No violations or deviations were identifie . QA Program The NRC inspector reviewed the licensee's QA audit and surveillance program regarding radwaste activities associated with liquid and gaseous effluent releases to determine agreement with commitments in Chapter 17 in the FSAR and the requirements in Section 6.5.2.8 in the T The NRC inspector reviewed the QA department organization, audit schedule for 1986, and the qualifications of auditor Audit and surveillance reports generated from QA activities performed during 1986 in the areas of radioactive waste management, control of effluent releases, and ODCM were reviewed for scope to ensure thoroughness of program evaluation and timely follow-up of identified finding No violations or deviations were identifie . Exit Briefing The NRC inspector met with the NRC resident inspectors and the licensee representatives identified in paragraph 1 at the conclusion on November 21, 198 The NRC inspector summarized the scope of the inspection and discussed the inspection findings, including the observations listed in paragraph 2.

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