IR 05000482/1990030
| ML20062B314 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/26/1990 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20062B311 | List: |
| References | |
| 50-482-90-30, NUDOCS 9010240225 | |
| Download: ML20062B314 (18) | |
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APPENDIX i
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U.S. NUCLEAR REGULATORY COMMISSION h
REGION IV.
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NRC-Inspection Report:
50-482/90-30
. Operating License:
NPF-42-
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' Docket:
50-482'
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E ILicensee: Wolf Creek Nuclear Operating Corporation (WCNOC)
.P.O. Box 411
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Burlington, Kansas 66839 q
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A Facility Name:, Wolf Creek Generating Station (WCGS)
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. Inspection At: WCGS Site, Burlington, Coffey County, Kansas E
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Inspection Conducted: ' July'30 through August 10, 1990 W
l Inspector:
W SL/
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~Rc'E. BaqV,, Senior Reactor Health Physicist D~a'te -
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-W Radiological Protection and Emergency:
Preparedness Section
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' Approved:
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[e-f-2440
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B. Murray, Chief 7[R io ogical Protection-and Date >
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Emergency Prepred e Section.
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~ Inspection Sunimary '
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Inspection' Conducted: July'30 through August-10,' 1990 (Report 50-482/90-30)
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' Areas Inspected: Routine', announced inspection of selected portions of the
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g radiologica.1 controis-program and liquid'and gaseous radioactive effluents
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. treatment systems, a
Resultsi.Within the areas-: inspected, one noncited violation of 10 CFR 50.71(e)
l Uailure to update the. Safety Analysis Report) and n'o deviations were
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identified.=
'Thil_icensee's-externalidosimetryprogramdidnotincludeallnational m
'i ivoluntary laboratory accreditation program (NVLAP) categories. Termination
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--reports have been corrected to indicate if termination whole body counts were.
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. performed.. The. respiratory protection management; statement did not address all
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' items 11n-10~CFR:20.103.
The licensee's posting and radiation controls were f
- adequate..Some; maintenance problems were experienced with the personnel
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' contamination-monitors. A liquid effluent radiation monitor had been installed l
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9010240225 901005 a
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PDR ADOCK 05000482
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- which-was;not'
- included in Technical Specification (TS). A new waste waterf
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treatment 1 system was not described in the Updated. Safety Analysis-~
~ Report (USAR). The calibration program Lfor the process; radiation monitors did.
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, not include a-three point verification on each range. The licensee'.has E
maintained'an acceptable compliance based radiation protection p ogram. The
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- liquid and gaseous effluent release program, which includes sampling'
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procedures, release permits, and instrument calibration-and testing, is a well
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2 documented and effective program.- Four open items are-identified in
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Lparagraph'3.
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DETAILS
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' Persons Contacted-
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' *B. D."W1thers,~ President.
- J. A. Bailey,- Vice President, Nuclear Operations m
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- R. S.-Benedict, Manager, Quality Control
- G. D. Boyer, Plant' Manager
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- H. K.' Chernoff, Supervisor, Licensing
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'*M.lE. Dingler,: Manager,-Nuclear Plant Engineering (NPE)
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- R.'D. Flannigan, Manager,' Nuclear Safety Engineering u-
- C. ' WC Fowler,. Manager, Instrumentation.and Controls (I&C)
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.J. D. Freeman, Radwaste Coordinator--
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. N. W. Hoadley, Manager, Plant. Design,'NPE
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- S.1A.. Henry,< Chemistry SupervisorL M
- R. LW.' Holloway,- Manager,: Maintenance and Modification
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- E. C. Holman,; Supervisor, HP
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- D. M-Hooper,' Engineering Specialist
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- W M. - Lindsay; Manager, Quality Assurance (QA)'
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- R. L.:Logsdon,' Manager, Chemistry-
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V. J. MacTaggart, Wichita Liaison, NPE l}
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- T. S. Morrill, Manager,-Radiation Protection-N.
iC. R Morris, Engineer, NPE, Wichita
- D J.lNsufeld, Shift' Supervisor-E
~*W. B. Norton,-Manager, Technical' Support j
- C.' L; Palmer, Chemistry Supervisor
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- J.: Pippin =, Manager, NPE D
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- R. Sims,LSupervisor, Equipment Engineering-
.B.. Smith', Manager, Modifications-
- C..M.-Sprout.--Section Manager, NPE g4
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- J. Stamm, Manager, System Engineering.
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\\*H. L. Stubby, Su'pervisor, Technical. Training y
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. S. W.~ Wideman,. Senior Engineering < Specialist
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G.- Williams,. Manager, Plant Support j
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mn J.~ A; Zell, Mutager, Training.
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o J. He Ziesenis,. Chemistry Supervisor
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i0thers l
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- L'.J.Gundrum, Resident 1 Inspector, NRC
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MM E. >Skow,1 Senior, Resident. Inspector, NRC
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.W. T.1Nabb,: Operator l, Duratek'
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SThe inspector also interviewed several other licensee employees inciuding.
Yf radiation protection,; operations, maintenance, I&C,-and administrative li
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- personnel.
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- Denotes those individuals present during the exit interview on August 10,-
1990.
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2.
Followup on Previous Inspection Findings (Closed) Open Item (482/8920-01):
Personnel Dosimetry Quality Control Test-This, item was previously discussed in NRC Inspection Report'- 50-482/89-20 and involved the lack of.a' time limit'for investigations and evaluations of thermoluminescent dosimeter (TLD)
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K intercomparisons which had a discrepancy greater than i 25 percent, T he' -
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licensee had revised Procedure HPH 01-017, Section 5.3.3 which now
' requires that discrepancies greater than i 25 percent be-investigated by a
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HP supervisor within.30 days.
(Closed)L0penItem(482/8920-03): High High Radiation Area Radiation Work a
Permits - This item was previously discussed in NRC Inspection Report 50-482/89-20 and involved-the use of-a single specific radiation work permit (RWP) for entry into-.high high radiation areas.- The licensee reevaluated the use-of a general:RWP for high high radiation area entries -
and' determined-that specific'RWPs would provide increased.HP control.7 A separate RWP had been initiated for each specific high-high radiation area; for. inspection. purposes only..an additional RWP would be initiated'for specific work functions in the area.
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.(Closed) Open Item (482/8920-06):
Plant-Safety Review ~ Committee's.
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Review --This item was previously discussed in NRC Inspection Report 50-482/89-20 and involved the use of vendor: procedures reviewed:and-U approved by the' Plant Safety Review-Committee (PSRC) which contained Y
- systemLdrawings,and checklists that'were generic in scope and did not.
accurately depict the system in use at the licensee's facility. The L11censee revised their program to ensure thatinew procedures:or revisions
- to existing procedures are:sent to the WCGS radwaste coordinator.
It.i s his responsibility:to discuss these changes'withithe vendor's system ope'rator and determine their applicability-toithe WCGS system.
Proposed
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a changesito operating procedures are'then sent to the PSRC for approval prior.to their implementation, t
i(Closed) Violation (482/8825-01):
Failure to Follow Procedures in Setting
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Continuousi AirborneL Radioactivity Monitor' Alarm Setpoint - This violation po was 'previously ~ discussed in:NRC Inspection Reports 50-.482/88-25 and 50-482/89-20 and involved the alarms on several continuous' airborne
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padioactivity-monitors (CAMS) that were incorrectly set high. One of the
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' CAMS would not respond to.an alarm test because.the alarm setpoint was set'
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.off-scale high. The licensee had implemented a change to
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Procedure HPH 04-077A " Operation of the Eberline AMS-3" which ensures'that proper alarm setpoints are established.
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<1 (Closed) Violation (482/9017-01):
Failure to Have Adequate Procedures'-
,79 This= violation was discussed in NRC Inspection Report 50-482/90-17 and
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involved the lack of Procedure ADM 03-600 to require sufficient Wf f information to verify that a respirator user is issued a respirator of the h
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- same model'and size for which he had been fit-tested.
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Procedure ADM 03-0600 had been revised and Section-4.2.2.1-now requires-the issuer to. verify-prior to issue that the respirator user receives-the" proper size (small', medium, large) and type (UV, UT) for which he has.been-fit-tested.
(Closed) Unresolved.(482-8920-07):. Applicability of.10 CFR 50.73 i
Requirements'to. Licensee Identified-TS 6.12 Violations - This unresolved
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item was discussed'in NRC Inspection Report 50-42/89-20 and involved'the-
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reporting of high high radiation area control violations by use of:the
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licensee event. report repo' ting requirements of 10 CFR'50.73. This matter-r was referred to the NRC's Office of Nuclear Reactor Regulation (NRR) for a
i formal position.
The NRR position is that future violations of TS 6.12
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shall.be' reported in accordance with the requirements-of 10 CFR 50.73.-
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Open Items Identified During This: Inspection
- f An open item isla matter that requires further review and evaluation-by
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the inspector or licensee. 0 pen items'are used to document,Ltrack', and
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ensure adequate followup on matters of concern to the inspector.
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following open items were identified.
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Open Item Title Paragraph'
482/9030 01'
Plant-Modif1 cation Request (PMR)
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System Update of USAR
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1482/9030-02 Generic.:. Letters 89-01 l8
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License. Amendment
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482/9030-03 Proce~ss Monitor
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Calibrations
482/9030-04 High Activity.
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Alarm Administrative Controls-1n
' 4; Licensee Event Report (LER) Followup
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LERJ90-015-00 was.-reviewed to determine that-reportability requirements:
- were fulfilled,,immediate corrective action was accomplished, and'
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corrective action to prevent recurrence had been accomplished in
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'accordance with the'TS.
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The.LER reported'the. licensee's misapplication of TS 4.0.2'in the-failure
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- to" sample the unit vent'for gaseous radioactivity at-'least once per
- h 12-hours while Radiation Monitor GT RE-21B was inoperable, as_ directed by
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R-the action statement:to TC 3.3.3.11.
There had been'aitime lapse of
- 13; hours between? samples collected on June 19, 1990..The licensee issued xF
' 3aDmanagement: letter (WO 90-0106) on July 27, 1990, to personnel-LresponsibleLfor performing surveillances clarifying the aplicability of y
- O-lTS 4.0.2tand emphasizing these provision do not apply to activities which
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j are conducted to' meet action requirements stated in Section 3 of.the TS.,
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The_ licensee revised Station Procedure ADM 04-020, " Chemistry Surveillance-Program,'!.Section: 2.6 which now states' that the extension allowed by TS.4.0.2 applies only to TS surveillance frequencies and not to TS action'
statement frequencies. This LER is considered.to be closed.
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External Radiation Exposure Control
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.The inspector reviewed the licensee's external radiation exposure control
program to determine compliance with 10 CFR Parts 19.12, 19s13, 20.101,
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20.'102,.20.'104, 20.105, 20.202, 20.203, 20.206,.20.405, 20.407, 20.408,
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20.409, and-50.73; Sections 6.11 and'6.12 of the TS;'and agreement with commitments contained in Chapter 12 of the.USAR.
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The inspector _ reviewed the licensee's personnel dosimetry program. The i
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inspector noted that the licensee had received the NVLAP certification for:
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their TLD program in'seven of the eight performance categories. The.
licensee had not! submitted to testing in Category III, low energy photons'.
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The inspector: discussed with licensee repr'esentatives the NRC recommendation for power reactor faci 11 ties to maintain accreditation in all eightiperformance categories.
The-licensee stated that they'would
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o, evaluate this recommendation.- The licensee's'present accreditation is
.vali.d through January,1, 1991~.
The inspector. reviewed personnel radiation exposure termination reports.
The inspector noted the licensee routinely printed under "other bioassay
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results" the phrase "no significant intake-was detected during the period i
covered by.this report"; even when a termination whole-body count had not
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been performed. : Discussions with licensee representatives-as to how this i
determination could be made without an exit whole body count prompted the
licensee # 1 change the report to state that an exit wholeibody count was-
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inot performed if the individual did not receive one. The inspector'noted
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that-this change was-implemented during the inspection.
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- The-inspector determined-that the licensee was a member.of'the Integrated
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- Nuclear Data Exchange (INDEX). The purpose'of INDEX is:to process a T
temporary, transient' worker in a more' efficient manner. The INDEX. system.
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is' utility owned by 12: utilities representing 19' nuclear > power plant sites R
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- and provides data in five categories:
personal information,, employment,.
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" security, training, and health physics. TheLHP data cludes radiation.
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exposure history data;1 respiratory physical certification' and fit testing;.
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- and training dates, scores, plant where completed, and plant' contact.
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Internal Exposure Control l.
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The-inspector reviewed the licensee's program for control of internal f
radiation exposure to determine compliance with the-requirements of _
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110.CFR' Parts 20.103, 20.203, 20.401,-and TS 6.11; and agreement with the f
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recommendations of Regulatory Guide (RG)~ 8.15', NUREG-0041, and Industry q
LStandards ANSI Z88.2-1980 and ANSI /CGA G-7.1-1989.
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TheLinspector reviewed--the -licensee's respiratory protection program..
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_ including policy statements, directives, implementing procedures, and'
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respiratory protection' equipment.- The inventory of respirators and
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training for individuals. involved with the maintenance and repair of, respirators and associated ~ support equipment was ! 9iewed and found to:be i
- adequate. 'The licensee maintains a sufficient sspp!y of respiratory-protective' equipment to support plant activities.
The licensee has maintained a. well. documented quality: control; program for respiratory
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protection equipment.
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The licensee maintains two policy statements.for respiratory protection equipment' usage.. The' inspector noted that the' first Operative
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Policy'II.2, " Radiation Protection," August 25, 1989, did not address.all the_ topics in 10.CFR Part 20.103(c)(3). The second directive. incorporated:
in the Radiation Protection Manual 1.0, Wolf Creek' Nuclear Operating:
Corporation, Wolf Creek Generating Station radiation protection program'
.l appeared' adequate.
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No violations or: deviations were identified.
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Control of Radioactive Materials and Contamination. Surveys, and
.l Monitoring
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L The inspectorLreviewed the licensee's program for the control of.
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. radioactive materials and. contamination, surveys, and monitoring to_
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. determine agreement.with the commitments contained in Chapters'11.4 and 12 of the USAR;; compliance ~with.the requirements contained in TS 3.7.9 and j
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,6.11, and 10 CFR Parts'19.14,E20.4,_20.5,_20.201, 20.203, 20.207,'20.301,_
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'20.401,-20.402, Land-30.51;.and-the recommendations of RGs 7.3~and 8.25,
.and Industry Standard ANSI N323-1970.
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- The; inspector reviewed the licensee's use of friskers'and personnel
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contamination monitors (PCMs) installed at the ' exit from the-a radiologically. controlled area- (RCA).
The inspector observed that only a'
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limited number:of. the PCMs were operational: and the' placement of these L
-monitors did not provide aniefficient flow' pattern'for potentially.
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contaminated and: clean personnel.
It was necessary for.personneixto cross
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paths to exit after theythad, monitored!themselves. 3The. licensee >had:
L experienced maintenance problems with the,PCMs, but plans to. purchase
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- additional units to. ensure that an adequate monitoring survey. program =is:
- maintained.-
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The 1nspector.revie'wed the licensee's. posting, radiation area controls, and housekeeping;within the RCA and determined that they were adequate.
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The-inspector observed personnel in the RCA were wearing proper dosimetry.
The licensee maintained an adequate supply of protective clothing and'
l equipment to support maintenance activities.
J No violations or deviations were identified.
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8.
Liquid'and Gaseous Waste Systems
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Theinspectorreviewedthelicensee'sliquidandl gaseous. radioactive
/I effluent programs including waste system changest waste samplingp process
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and effluent monitors, procedures for waste and effluent systems, and air
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cleaning systems to-determine agreement with commitments in Chapters 9
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and:11Lof the USAR; compliance with the requirements in
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i Sections-3/4.3.3.'10,.3/4.3.3.11, 3/4.7.6, 3/4.7.7, 3/4.11.1, 3/4.11.2,
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6.5..and 6.8 of the TS;-and agreement with the recommendations of RG 4.15.
l The inspector = reviewed the licensee'.s gaseous and liquid radioactive waste effluent monitors' functienal checks,~ calibrations, and alarm setpoint
' determinations. :The licensee's records-indicated that the frequency of the calibration and functional checks were.within the-applicable TS:
requirements. lThe insrsector determined-that a new radiation monitor
HF-RE-95'had been instelled'in November 1988, and had been calibrated on i
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November 29, 1988, and August'28,'1989, the same frequency as other plant
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- ef fluent monitors. A review of-the USAR did not provide any information'
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as to the function, location, or purpose of this monitor. The inspector determined that Radiation Monitor HF-RE-95 was located on the 2000-foot elevation:of the turbine building and was considered an' effluent monitor.
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<by1the licensee.
Theilicensee had-~ constructed a waste water treatment ~ system. The
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construction activities associated with this system were. accomplished
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under plant modification request.(PMR) PMR 84-075'.
Construction started in 1987 and the system has been' receiving waste water since Marche 1989.
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!The. waste. water treatment systemLis designed-to process-the chemically
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. contaminated liquids ; generated by plant operations and allow these liquids -
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to be discharged tolthe-environment. The system: treats waste liquids.
j from:..the makeup water treatment system, demineralizer regenerant liquids
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,and filter backwashes,and. rinses;1 condensate demineralizer system, high total-dissolved solids from demineralizer chemical regeneration and-low mc total dissolved solids from demineralizer backwashes and rinses; shop-.
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building, acid and ' caustic skid floor drains; and ' secondary liquid waste L
' system'oi1~and water separator effluents.
The system chemically b[
' neutralizes the wastelliquids prior to their: release to the WCGS cooling
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The major. components of the waste water treatment system consist of:
300,000 gallon mixing and storage basins
Motor-operated agitators (2 per basin)
Recirculation and discharge pumps
Acid storage tank and feeder pump
Caustic storage tank and feeder pump The Rao.ation Monitor HF-RE-95 was installed in the discharge line to the waste water treatment system and a high radiation alarm will cause an automatic isolation of the discharge by closing Valve HF-RV-95.
The inspector discussed with licensee representatives that the waste water treatment system was not discussed in the USAR.
The licensee stated that
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PMR 84-075 had-not been completed ar operating as designed. The PMR
>i indicated a status of "AP6, released for implementation," for-the system.
The system had not met or been accepted by the Kansas State Department of-He al th'.
The licensee was presently routing the effluents from the waste water treatment system to the lime sludge pond which discharged into the WCGS cooling lake.
10 CFR Part 50.71(e) states, in part, that the Final Safety Analysis Report shall be updated annually and shall reflect all changes made in the a
facility.
The inspector discussed with licensee representatives that the USAR is the primary mechanism that the' Regional Office and Headquarters, Office of Nuclear Reactor Regulation (NRR) use to know what changes the licensee has
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made to their facility and 10 CFR Part 50.71-sets specific requirements
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for reporting changes.
The failure to-update the Final Safety Analysis
Report to include the new waste water treatment system is considered a
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violation of 10 CFR Part 50.71(e); however, in accordance with 10 CFR Part 2,LAppendix C,Section V.A. of the NRC Enforcement Policy,.no citation is being issued for this violation. The inspector discussed with r
the licensee the need to review the process for submitting information to
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NRR and updating the USAR in a timely manner, and to review all PMRs that are being held in the AP6 status for similar untimely notification. The licensee committed at the exit interview on August 10,'1990, to review the PMRs by September 1, 1990. The review of PMRs, the inclusion of the waste
"5 water treatment system in the USAR update,'and'the review of the process
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for submitting information to NRR and updeting the USAR is considered an Open Item (482/9030-01).
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The inspector reviewed the semiannual radiological effluent release
. reports for the period of January 1, 1988, through December 31, 1989. The
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l licensee noted in Report Number 8 for the period-July 1 to December 31, 1988, "the addition of Radiation Monitor.HF-RE-95 (waste water treatment)
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to~ monitor the discharge of condensate polisher regeneration waste to the new waste water treatment facility.
Its setpoint description is identical L
to'that of the turbine building Sump Monitor LE-RE-59.
This radiation monitor was added to prevent accidental contamination of the waste water
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treatment system." The inspector noted that Radiation Monitor HF-RE-95 i
had:been included in Section 2.1.1, continuous liquid' effluent monitors of
,the Offsite Dose Calculation Manual (ODCM), Revision 4~, November 4, 1988.
The. inspector discussed with licensee representatives the absence of any-
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reference to Monitor HF-RE-95 in Section 2.4, " Calibration of Liquid.
Effluent Monitors." The licensee stated that this had been an oversight
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and would be corrected as part of the submittal for the transfer of the Radiological Effluents Technical Specifications (RETS) to the ODCM per
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ueneric Letter 89-01.
The inspector noted that Radiation Monitor HF-RE-95 had been calibrated in accordance with Procedures STS10-461, " Channel Calibration HI/LO TDS
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Discharge to Waste Treatment Radiation Monitor HF-RE-95," Revision 0, August 3, 1985, and STS CH-010, " Calibration of Liquid Process and Effluent Monitors," Revision 3, September 19, 1989, and surveillance
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tested on a 3-month frequency in accordance with STS-IC-261, " Analog Channel 0perational Test High and Low TDS Discharge to Waste Treatment Radiation Monitor HF-RE-95," Revision 1, July 5, 1989.
The inspector discussed with licensee representatives that the-licensee had classified Radiation Monitor HF-RE-95 as an effluent monitor in November 1988 and as such, in accordance with 10 CFR Part 50.34a, should i
be included in the TS which would provide for calibration, surveillance, and operating limits when the monitor was out of service. The licensee stated that the monitor had been discussed with NRR prior to the issuance
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of Generic Letter 89-01 and the licensee should include this monitor with
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their Generic Letter 89-01 submittal. Generic Letter 89-01 was issued on January 31, 1989, and as of August 10, 1990, the licensee had not submitted the license amendment request. The inspector requested a commitment from the licensee that a TS change or license amendment be g
submitted for Radiation Monitors HF-RE-95 to include it in the ODCM and
ensure the monitor is provided the same calibration and surveillance
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l requirements afforded.other effluent radiation monitors.. The licensee
. committed at the exit-interview on August. 10, 1990, that the license
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amendment request addressed in Generic Letter 89-01 would be submitted to.
- NRR prior to September 1, 1990.
This is considered an Open Item pending the submittal of the licensec's response to Generic Letter 89-01
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(482/9030-02).
The inspector reviewed the calibration of process radiction monitors. The licensee had completed a QA Surveillance TE:53359 S-1846, " Calibration of
Process'and Effluent Monitors," in June 1990 and identified that the i
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. calibration of the process monitors was inadequate.
The licensee was
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L performing an electronic calibration of the unit with a single source, I
~ ingle point, calibration of the detector. The licensee had changed s
sources from the original source that had been used during the initial l full range calibration with radioactive liquids and gases.
Industry Standard ANSI N323-1978 specifies that a radiation monitor should be calibrated, at a minimum, at three points, approximately 20, 50, and 80 percent, over the full range of the instrument and ideally would include
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at'least two different energy levels.
The QA department is trac'.ing the
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resolution of.the process radiation monitor calibrations on QPD'7/90-058.
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The inspector stated that calibrations of the process radiation monitor is.
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considered an Open Item (482/9030-03) pending resolution of QPD 7/90-058.
The inspector also reviewed the STN IC-500 series of calibration procedures for.the area radiation monitors.. The inspector determined that those procedures, written between 1986 and 1989, required a three point =
calibration of the detector (0.6 or 0.8, ~20.0, and 200.0 milliroentgen per hour [mR/hr]) and procedures written after January 1,1990, directed that calibration of the detector be performed at 0.8, 2.0, 20.0, 400, and
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8000 mR/hr. The inspector stated that having two different levels of calibration for the same type of equipment could lead to confusion for personnel performing these calibrations. The licensee stated that they
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sould evaluate this concern.
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The inspector requested the. licensee to evaluate the location of Radiation Monitor HF-RE-95 in relationship to the Isolation Valve HF-RV-95 and determine if the valve would close in sufficient time to prevent the discharge of radioactive material to the waste water treatment system upon activation of a high activity alarm. The licensee, at the exit interview,
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stated that the isolction valve would not close in sufficient time and
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some of the effluents would be discharged. The licensee stated that
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additional administrative controls would be provided for the system. This
.is considered and Open Item pending the inspector's review of the implementation of administrative controls regarding the high activity
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alarms on Effluent Monitor HF-RE-95 (482/9030-04).
l The inspector reviewed the licensee's procedures, surveillance tests, and J
selected records and test results for maintenance and testing of aircleaning systems which contain high efficiency particulate air (HEPA)
filtert and activated charcoal adsorbers. The inspector verified that the
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11censee's procedures and surveillance. tests provided for the required periodic functional checking of ventilation system components, evaluation of HEPA and activated charcoal adsorbers, and in place filter testing of
-the filter systems. The inspector. reviewed records and test results for'
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the period September 1989 through July 1990 for the main control room emergency ventilation and the auxiliary building emergency exhaust aircleaning systems.
The in place filter testing and activated charcoal-laboratory tests had been performed in accordance with approved procedures and the test results were verified to be within TS limits.
The licensee
_had performed QA audits on the contractor performing tests on the ventilation systems and had placed the contractor on the station's
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qualified supplier list.
No other violations or deviations were identified.
9.
Organization and Management Controls L
The inspector reviewed the licensee's organization, staffing, and staff I
functional assignments related to the liquid and gaseous radioactive waste l
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and 13.5 of the USAR and compliance with the requirements in Section 6.2-l of the TS.
l This inspector verified that the organizational structure of' the redwaste-operations section responsible for the performance of the liquid and-i gaseous radwaste program were as defined in the USAR.
The organizational
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structure and staffing appeared sufficient to meet the requirements for
.I the routine performance of the liquid and gaseous radwaste activities.
i The inspector verified that the administrative control responsibilities
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specified'in station procedures were being implemented.
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No violations or deviations were identified.
10. Training and Qualifications y
The inspector reviewed the licensee's training and qualifications' program-
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for nonlicensed nuclear equipment operators responsible for conducting
liquid and gaseous radwaste activities to determine agreement with
commitments in Chapter 13 of the USAR and compliance with the requirements
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in Section 6.3 and 6.4 of the TS.
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The inspector determined the nonlicensed nuclear equipment operator training program was being implemented in accordance with station procedures.
The training program had been rodified and implemented to
include the new waste water treatment system in November'1987.
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No violations or deviations were identified, i
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11. Audits and Appraisals The inspector reviewed selected audits and surveillances of the licensee's radiation protection and liquid and gaseous radwaste-management programs.
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conducted from September 1989 through July 1990. The specific documents
reviewed are listed in the Attachment. The audits and surveillances were
reviewed for their scope and extent, qualifications of the auditors, and adequacy of corrective actions.
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The inspector noted the licensee had a technical expert as a member of the j
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audit team.
This individual-had extensive experience at a power reactor
facility. The audits and surveillances appeared to be well planned and performed in accordance with the licensee's approved quality assurance-program. The audit teams used a checklist which appeared to adequately cover all areas of the radiation protection and liquid and gaseous radwaste management programs.
No violations or deviations were identified.
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Exit Interview
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The. inspector met with the resident inspector and licensee representatives identified in paragraph 1 of-this report at the conclusion of the ir,spection on August 10, 1990..-The inspector summarized the scope of-the
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inspection and discussed the inspection findings'as presented in this report. The inspector received commitments from the licensee regarding the following items:
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Plant Modification Request:
The licensee indicated that the process for submitting information to NRR and updating the USAR in a timely; manner would be reviewed. The licensee also committed to-reviewing
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all PMRs in the ApG status for timely notification and to submitting
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the USAR update for the work done under PMR-84-075 by September 1, i
1990.
Monitor HF-RE-95:-.The inspector requested a date when the licensee-would provide the Radiation Monitor HF-RE-95 package to NRR via a TS or ODCM/RETS change that would-include the same calibration and j
surveillances' required presently in effect for other effluent radiation monitors. The licensee stated that this information would be submitted before September 1, 1990.
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Isolation Valve HF-RV-95: The licensee had determined that Isolation-d Valve HF-RV-95 would not close in sufficient time to prevent the
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discharge of radioactive material to the waste water treatment system upon activation of a high activity alarm,. The-licensee stated that additional administrative controls would be provided to prevent this from happening.
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The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during the inspection.
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ATTACHMENT DOCUMENTS REVIEWED TITLE.
REVISION DATE Operative Policy 11.2 Radiation Protection
8/4/89 ADM 01-094 Evaluation of Air Contaminants and Respirator Selection
2/9/90
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ADM 01-098 Respiratory Protection Program Beard Policy I'
7/11/90 ADM 03-002 Radiation Worker Guidelines
3/21/89 ADM 03-007 Duties and Responsibilities of-Health Physics Supervisors and Technicians
.7/11/90 ADM 03-100 Health Physics Dosimetry Program
3/14/90 ADM 03-101 Radiation Work Permit Program
5/23/90.
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ADM 03-104 Control of High High Radiation Areas
5/23/89
ADM 03-105 Radiation Work Permit Request
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Program-
7/11/90
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I ADM 03-202 Radiological Control and Unconditional Release of Tools and Equipment
3/28/90
ADM 03-400. Operation and Calibration of Health
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Physics Equipment
6/13/90 7/1'/90 ADM 03-600 Respiratory Protection Program
1 ADM 03-950 Radioactive. Waste Program
9/12/89 HPH 01-001 Issuing and Numbering of TLDS
2/22/90 g
HPH 01-002 External Overexposure Evaluation
3/3/89
- HPH 01-004 Acceptance Criteria for Panasonic TLDs Monitoring Devices'
3/7/89 HPH 01-006 TLD Processing
3/7/89 L
HPH 01-008 MPC-Hour Tracking
4/3/89 L.
L HPH 01-012 Internal Exposure Calculations L
and Evaluation
4/2/90 l
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TITLE REVISION-DATE
~ HPH 01-017-Evaluation of Personnel TLD Monitoring Devices-
4/26/90'
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HPH 01-019 Exposure History Files
6/7/89'
HPH 01-035 Dosimetry 1n Non-Uniform
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Radiation Fields
2/16/90
' HPH 01-036 National Voluntary Laboratory Accreditation Program
5/9/89
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HPH 01-037 Operation of the Index Computer
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System in Health Physics.
I 7/12/90 HPH 03-002 Radiation Survey Methods
3/31/90
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HPH 03-003 Airborne Radioactivity Survey
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Methods
3/22/89 HPH 03-011 Contamination. Survey Methods
6/22/90 HPH 03-012 Schedule of Routine Radiological Surveys'
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~6/12/89-HPH 03-014 Personnel Decontamination-
11/22/89 HPH 03-015 Posting for Radiological Controls
4/21/89-HPH 03-027 Skin Dose-Calculations
9/22/89 HPH 03-028 Free Release of Trash
2/5/90-
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' HPH 04-77A Operation of the Eberline AMS-3
1/22/90 HPH 04-778 Calibration of the Eberline AMS-3
9/6/89 HPH 04-085A Operation of HP Trash Monitor Table
4/2/90
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- HPH 04-085B Calibration'of HP Trash Monitor Table
1/18/90
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i HPH 06-004 Selection of Respiratory Protection Equipment-
2/26/90 HPH 06-011 Quality Control of Respiratory Protection Equipment
4/4/90 t
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. TITLE REVISION DATE.
HPH 06-014 Calibration of Quantitative Respirator Fit Test System
5/22/90 HPH 06-019 Procurement, Issue, and Use of GMR-1 Iodine Canisters
8/1/90-HPH 09-543 Operation of the Hot Machine Shop Decon Equipment
1/9/90
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HPH 09-545 Maintenance of~ Vacuum Cleaners Used in the RCA
12/12/89:
KGP-1131 Plan Modification Process
12/4/89 STN 10-471 Channel Calibration Steam Generator Blowdown Process Radiation Monitor BMRE25
6/11/85
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STN IC-472 Channel Calibration Boron Recycle Evaporator Distillate Radiation Monitor HERE16
6/6/85 STN IC-476 Channel Calibration Essential Service-Water System' Radiation Monitor EFRE36
7/5/89 STN 10-477 Channel Calibration Service Water System Radiation Monitor EARE04B
4/30/90-
'STN IC-482 Channel Calibration Radwaste Building Exhaust Radiation Monitor GHRE22
10/6/87-STN IC-483 Channel Calibration Access Control Area Ventilation Exhaust Radiation Monitor
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GKRE41
6/11/88 s
STN IC-484 Channel Calibration Auxiliary Building Ventilation Exhaust Radiation Monitor GLRE60
6/14/85 STN IC-500 Channel Calibration Radwaste-Building Corridor Basement Area Radiation Monitor SDRE01
'2 1/25/90 STN IC-511 Channel. Calibration Auxiliary Building Corridor Basement Area Radiation Monitor SDRE12
8/1/89 STN 10-531 Channel Calibration Control Building Corridor Area Radiation Monitor SDRE32
3/24/90
.STS CH-010: Calibration of Liquid Process and Effluent Monitors
9/19/89
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-4-TITLE REVISION DATE STS CH-011 Calibration of the Particulate Detector for Gaseous Monitors
4/26/88 i
STS CH-012 Calibration of the Iodine Detector
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for Gaseous Monitors
8/1/90 STS CH-013 Calibration of the Gaseous Detector for Gaseous Radiation Monitors
1/2/90 STS CH-014. Calibration of Monitors GT RE-21B and GH RE-10B
1/2/90 STS GT-205 Containment Purge System Inservice Valve Test
6/24/86 STS HB-201 JLiquid Radwaste System Inservice
' Valve Test
'1/26/87 STS IC-450A; Channel Calibration Containment Atmosphere,and RCS. Leak Detection Radiation Monitor GT.RE-32
3/24/89 STS 10-4508 '. Channel Calibration Containment Atmosphere and RCS Leak Detection Radiation Monitor GT RE-31-
3/24/89 SB IC-452A Channel Calibration New Fuel Pool
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Criticality Monitor SDRE35
2/2/90 STS 10-455B Channel Calibration Control Room Air Intake Radiation Monitor GK RE-04
5/23/89 STS.IC-458 Channe1' Calibration Turbine Building Effluent Radiation Monitor LERE59
7/21/89 STS IC-566 tiquid Radwaste System Discharge Line-Flow Rate Calibration
4/26/85 STS'IC-567 Steam benerator Blowdown System Flow Channel. Calibration
12/7/88 STS10-568 Secondary. Liquid Waste System Discharge Line Flow Calibration
1/2/90 AUDITS AND SURVEILLANCES l
TE:50140-K285 Radiation Protection, May 1-31, 1990 TE:50140-K289 Environmental Rad Protection and ODCM, June 4-28, 1990 L
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-5-r AUDITS AND SURVEILLANCES
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TE:50140-K280 Work Controls, March 6-30, 1990'
TE:53359 S-1765 Plant Operations During Waste Processing, October 26 - November 1, 1989
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TE:53359 S-1759 Low Level Waste Processing, October 16-20, 1989 TE:53359 S-1785 Health Physics Dosimetry Program, February-12-28,1990
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TE:53359 S-1788 Pre-Outage Work Activities, March 5-9, 1990 TE:53359 S-1797 General Outage Activities, March 12-22, 1990 TE:53359 S-1818l Contamination Controls, April 13-17, 1990 TE:53359 S-1812 Radwaste Processing, April 23-25, 1990 TE:53359 S-1838 Radioactive Waste Shipment G0034, May 18-24, 1990 TE:53359 S-1846 Calibration of-Process and Effluent Monitors, June 8-29, 1990
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Lesson Plan LR 13 104 03, " Wastewater Treatment System" Lesson Text LR 13 104 03, " Wastewater Treatment"
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