IR 05000482/1993017
| ML20045H341 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/13/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20045H334 | List: |
| References | |
| 50-482-93-17, NUDOCS 9307200108 | |
| Download: ML20045H341 (10) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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I Inspection Report:
50-482/93-17
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Operating Licenses: NPF-42 Licensee: Wolf Creek Nuclear Operating Corporation
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P.O. Box 411 Burlington, Kansas ~ 66839
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Facility Name:
Wolf Creek Generating Station Inspection At:
Coffey County, Kansas Inspection Conducted:
June 28 through July 2, 1993 Inspector:
L. T. Ricketson, P.E., Senior Radiation Specialist
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Facilities Inspection Programs Section
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Approved:
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B. Murray, Chief / Fa/il yes Inspection Date Programs Secti'on J_ntspection Summary
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Areas inspected:
Routine, announced inspection of the radiation protection t
program, including audits and appraisals, training and qualifications, external exposure controls, internal exposure controls, controls of
radioactive material and contamination,' and program for-maintaining radiation l
exposures as low as reasonably achievable (ALARA).
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Results:
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The quality assurance audit of this area was comprehensive and
identified areas of possible program improvement.
The audit team
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included a technical expert from another operating facility.
The
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radiation protection organization responded quickly to the audit findings (Section 2.1).
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A new ALARA coordinator was selected and the ALARA organization was
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enlarged (Section 2.2).
The licensee continued modifications of the radioactive waste building
to increase the interim waste storage space (Section 2.2).
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Preparations were underway to implement the new 10 CFR Part 20 on i
January 1, 1994 (Section 2.2).
9307200108 930714 PDR ADOCK 05000482 G
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-2-Both permanent and contract radiation protection technicians met
qualification requirements (Section 2.3).
State-of-the-art personnel dosimetry was used.
The accreditation of the
program was extended to January 1994 (Section 2.4).
A good radiation work permit program was implemented (Section 2.4).
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Problems with the licensee's planning and scheduling organization had
the potential of preventing work packages from reaching the ALARA group with time for proper review; however, this was beyond the control of the radiation protection organization (Section 2.4).
Dosimetry records were complete (Section 2.4).
- Posting of radiation areas and control of locked high radiation areas
were excellent (Section 2.4).
Comprehensive programs for whole body counting, air sampling, and
respiratory protection composed an excellent internal exposure control program (Section 2.5).
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Excellent radiation survey.and instrument calibration programs were in
place (Section 2.6).
Housekeeping in the radiological controlled area during routine
operations was very good (Section 2.6).
Primarily because of forced outages, the licensee exceeded its 1992
person-rem goal (Section 2.6).
Because of a reduction in the scope of work performed, the person-rem
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goal for Refueling Outage VI was not particularly challenging (Section 2.7).
Summary of Inspection findings:
Licensee Event Report 482/92007 was closed (Section 3).
Attachment Attachment - Persons Contacted and Exit Meeting
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t-3-i 1 PLANT STATUS During this inspection, the plant was operating normally at 100 percent power.
2 OCCUPATIONAL RADIATION EXPOSURE (83729 and 83750)
The licensee's program was inspected to determine compliance with Technical Specifications 6.3, 6.4, 6.5, 6.8, 6.11, and 6.12, and 10 CFR Part 20, and agreement with the commitments of Chapter 12 of the Updated Safety Analysis
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Report 2.1 Audits and Appraisals The inspector reviewed the quality assurance audit of the radiation protection program performed in May 1993.
The audit team included the radiation protection manager from another Region IV operating facility as a technical
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expert.
The audit was comprehensive and included suggestions for possible
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program improvements, i
findings to which the radiation protection organization had to respond were identified through the use of Performance Improvement Requests.
(This was the same plant-wide method as was used for the routine reporting of unsatisfactory
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conditions or performance.) One of the Performance Improvement Requests (93-0465) was closed during the course of the audit. Another (93-0469),
dealing with a typographical error, was redirected for response to the responsible organization.
The response for the third finding (93-0466) was
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not yet due.
The inspector reviewed quality assurance surveillance reports and noted that the reports were of good quality and provided management with a meaningful evaluation of daily operations involving the radiction protection
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organization, lhe inspector reviewed selected performance improvement requests and noted that the investigations of the events and the root cause analyses were-thorough.
2.2 Changes The licensee named a new ALARA coordinator.
The individual was formerly the
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health physics operations supervisor.
The ALARA group was expanded to include H
five technicians under the supervision of the ALARA coordinator.
One technician was primarily involved with the planning and. scheduling organization and the preparation of radiation work permits.
Another was responsible for post-job reviews, ALARA suggestion reviews, and shielding packages.
The other three technicians provided job coverage for work
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t performed in accordance with specific radiation work permits during routine operations.
The ALARA coordinator also had responsibility for the respiratory i
protection program.
The inspector noted the increased use of computers for tasks such.as calculating maximum permissible air concentration levels, tracking and
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-4-inventorying radiation sources, scheduling instrument calibrations, and i
maintaining technician qualifications.
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Modifications were underway in the radwaste building to increase interim storage area.
The projected completion date was the end of August 1993.
t Health physics personnel were developing procedures for the receipt,. storage,.
and inventory of waste.
Licensee representatives stated that procedure changes to-implement the new 10 CFR Part 20 changes were ready for comment.
Computer software changes were in the initial stages. Although detailed training had not begun, workers were being introduced to some of the new terminology during general employee,-
radiation worker, and respiratory protection training. The licensee also plans to use its onsite television system to inform workers of changes as the January 1994 implementation date approaches.
2.3 Training and Qualifications of Personnel The inspector reviewed the qualifications of selected individuals who had i
joined the radiation protection staff since the previous inspection and determined that they met qualification requirements.
Additionally, af ter
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selecting names from radiation survey and air sampling records, the inspector reviewed the technicians' qualifications, as listed on the qualification / task.
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matrix, and verified that the individuals were. qualified to perform the tasks assigneJ.
The inspector noted that the health physics operations supervisor did not have a current copy of the technician qualification / task matrix, listing the technicians and the tasks for which they were qualified. The list available was dated November 3, 1992.
This document or its periodic update were not required by procedure; however, the licensee took immediate actions to enable the health physics operations supervisor to access a current listing via a computer terminal.
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The inspector also reviewed selected resumes of contract radiation protection technicians used to supplement the permanent staff during the refueling outage
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and determined that they met qualification requirements.
2.4 External Exposure Control The dosimetry program remains as described in NRC Inspection Report 50-482/92-17.
The dosimetry program's accreditation was extended until January 1994.
The inspector reviewed various aspects of the radiation work permit program, including permits issued for some of the higher dose jobs worked during Refueling Outage VI.
The inspector determined that the information necessary for proper job planning was included in the packages.
ALARA representatives used a checklist to ensure completeness and consistency of the packages.
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lessons learned were incorporated and information from similar operating facilities was considered for infrequently performed work.
To ensure that
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-5-consistent information was provided to workers, outlines were used by individuals presenting briefings at ALARA prejob meetings.
The inspector determined that approximately 300 of 800 radiation work permit requests were submitted within the last 30 days before Refueling Outage VI.
Such a situation could lead to the inadequate review of the radiation work-i permit requests and failure to incorporate dose saving measures.
The inspector noted that Section 5.4.3.1 of Administrative Procedure ADM 01-108,
" Outage Planning and Implementation," stated, "Five (5) months prior to the
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outage scheduled start date... the Outage Planning Group members are.
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responsible for preparing and submitting to the Outage Manager a list of all known significant work activities that are to be accomplished during the outage." Section 5.4.6.1 stated, " Thirty (30) days prior to the outage scheduled start date... all work packages scheduled to be accomplished
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during the outage should be complete and ready to work."
It was clearly the intent of the licensee to ensure that the work packages were completed in time to permit an adequate review with the radiation work permit requests.
This
item was discussed during the exit meeting and licensee representatives stated
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that they were investigating problems within their planning and scheduling organization in attempt to improve its performance.
Licensee representatives i
stated that a similar problem existed during routine operations, as well, and this was also being evaluated.
During the exit meeting, the inspector stated that this observation was not intended to be a criticism of the radiation protection program, since it was beyond the control of the organization.
The inspector reviewed dosimetry records and reports sent to workers who had terminated employment and identified no problems.
Radiation exposure reports were reviewed routinely by the health physics support supervisor.
No one had exceeded regulatory radiation dose limits.
The inspector toured the radiological controlled area and reviewed area posting and identified no problems.
The inspector noted the extensive posting of current survey information at the entrances to various rooms.
The inspector also reviewed locked, high radiation areas and determined that they were properly controlled.
2.5 Internal Exposure Control The inspector reviewed the licensee's procedure for the!startup, energy calibration, background determination, and operation-of the whole body counter-(RPP 05-705, "ND Whole Body Counter Operation," Revision 1) and through a review of records and direct observation confirmed that it had been properly implemented.
Licensee representatives stated that they had identified no one with internal depositions of radioactivity in excess of their investigational limits.
The inspector reviewed results of the radiological air sampling program and noted the use of a computer program to calculate gross maximum permissible air concentrations.
Because the program would not accept identification numbers of air sampling instruments out of calibration, it aided in ensuring that proper instrumentation was used.
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-6-Through a records review, the inspector confirmed that air from the bottle filling station had been sampled according to procedural requirements and met Class D standards as set forth in industry standard ANSI /CGA G7.1, " Commodity Specification for Air."
The inspector confirmed that regulators on self-contained breathing apparatuses were bench tested annually to ensure proper operation,.in'
accordance with manufacturers recommendations.
The inspector also confirmed that the regulators were overhauled every 3 years, and the cylinders.were properly hydrostatically tested.
2.6 Control of Radioactive Materials and Contamination, Surveying, and Monitoring The inspector reviewed radiation survey records and determined that the surveys had been performed in accordance with the requirements _in Procedure RPP 02-205, " Radiological Survey Frequency Requirements,"
Revision 2.
A master list was used to designate areas to be surveyed on a daily, weekly, monthly, or quarterly basis.
Survey records included all necessary information.
While verifying the qualifications of individuals performing radiation surveys, as described in Section 2.3, the inspector identified a signature on a survey record which the licensee representatives could not identify. The signature was that of a contract health physics technician who had been employed during the refueling outage.
Licensee representatives stated that during the outage, a signature list was maintained for identification purposes; however, the list was not available at the time of the inspection.
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Licensee representatives stated that they would evaluate the need to maintain
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the signature list as a permanent record.
From the survey records, the inspector noted serial numbers of instruments used and then verified that the portable survey _ instruments, air samplers, and counting equipment were all properly calibrated.
The inspector also reviewed the calibration of gamma sensitive portal monitors and beta sensitive -
personnel contamination monitors and determined that they, too, had been properly calibrated.
The licensee used a computerized tracking system to ensure that instruments in use were within their required calibration intervalt.
The survey instrument calibration program followed the guidance of industry standard ANSI N323, " Radiation Protection Instrumentation Test and Calibration."
In order to review the calibration of pocket ion chambers, the inspector selectively noted serial numbers of those available to individuals entering the radiological controlled area.
Procedure RPP 06-415, "PIC Dosimeter Quality Testing," required that calibration be performed every 6 months.
All, except two, pocket ion chambers were found to have been calibrated within the previous 6 months.
The two devices found not to be in calibration were 200 '
millirem pocket ion chambers rather than the 500 millirem pocket ion chambers currently in service.
The 200 millirem chambers were supposed to have been out of service since february 1993.
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-7-Licensee representatives stated that the pocket ion chambers could have been returned late by workers who had-previously worn them from the radiological controlled area.
There was neither positive control of pocket ion chambers, nor was there a record to link the user identifications with the unique identification number of the pocket ion chambers.
Although this item was discussed during the exit meeting, it was not identified as a violation, because the two pocket ion chambers appeared to be isolated examples and there did not appear to be a general problem with the calibration of pocket ion chambers. Additionally, the inspector could not establish that the pocket ion chambers had been used by workers after the calibration expired because of the lack of user / pocket ion chamber linkage discussed above.
Licensee representatives stated that they would eventually be using electronic, alarming dosimeters for all personnel entries into the radiological controlled area.
On tours of the radiological controlled area, the inspector noted that housekeeping was very good in all areas except the radwaste building where construction and modifications were being perforned.
The inspector reviewed Licensee Event Report 482/93-006 which detailed the discovery of a hot particle on a nonlicensed operator who was filling and venting the safety injection system, inside containment. This report was initially discussed in NRC Inspection Report 50-482/93-08.
The licensee identified the particle as a fuel fragment and' calculated the exposure to the operator's skin to have been 33.9 rems (8 microcurie hours).
It did not appear that the corrective actions taken with regard to Licensee Event Report 482/92-007 (discussed in Section 3) would have prevented this event.
The licensee had not completed its implementation of proposed corrective actions; therefore, this item will be reviewed during a future inspection.
The licensee reported 53 personnel skin contaminations in 1992.
Through the end of the second quarter of 1993, a period which included a refueling outage, the licensee recorded 115 personnel skin contaminations.
2.7 Maintaining Occupational Exposure ALARA The licensee radiation exposure goal for 1992 was 16.6 person-rems.
The actual accrued exposure was 69.796 person-rems.
Routine operations were responsible for 11.126 person-rems.
Unpredicted factors contributing to the remainder of the dose were:
Refueling Outage V extending into 1992 and two forced outages occurring during the year.
Refueling Outage VI was conducted from March 4 to May 12, 1993.
The radiation exposure goal for the outage was 249 person-rems.
The ; ctual exposure was approximately 167 persor-rems.
The scope of the outage work was reduced, but the person-rem goal was not.
Through the end of the second quarter 1993, the licensee had accrued approximately 173 person-rems.
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-8-Licensee representatives stated that several current industry technologies were used during the latest refueling outage to reduce the total exposure.
These included the use of approximately ten television cameras to monitor activities in higher dose areas, wireless microphones to enhance communications, and telemetric dosimetry to monitor radiation exposure remotely.
2.8 Conclusions The quality assurance audit of this area was comprehensive and identified areas of possible program improvement.
The audit team included a technical expert from another operating facility. The radiation protection organization responded quickly to the audit findings.
Both permanent and contract radiation protection technicians met qualification requirements.
Portions of the external exposure control program examined during this inspection, such as dosimetry, dosimetry records, radiation work permits, area posting, and control of high radiation areas indicated the implementation of an excellent program.
Problems with the licensee's planning and scheduling organization had the potential of preventing work packages from reaching the ALARA group with time for proper review; however, this was beyond the control of the radiation protection organization.
Comprehensive programs for whole-body counting, air sampling, and respiratory protection composed an excellent internal exposure control program.
Excellent radiation survey and instrument calibration programs were in place.
Housekeeping in the radiological controlled area during routine operations was very good.
Primarily because of forced outages, the licensee exceeded its 1992 person-rem goal.
Because of a reduction in the scope of work performed, the person-rem goal for Refueling Outage VI was not particularly challenging 3 ONSITE REVIEW 0F LICENSEE EVENT REPORTS (92700)
(Closed) Licensee Event Report 48_2.]92-007:
Hot Particle Picked Up During Reactor Coolant System 'ihim Restraint Rework This event, involving an individual's skin dose as the result of exposure to a hot particle, was originally discussed in NRC Inspection Report 50-482/92-05 with followup in NRC Inspection Report 50-482/92-17.
Corrective actions were not completed before the reports were issued.
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Thr inspector reviewed the licensee's subsequentLcorrective actions and de'. ermined:
Hot particle surveys of the area which was the suspected source of the
particle were performed during a forced outage on November 10,.1992, but no additional hot particles were identified.
The definition of a hot particle used in procedure'RPP 02-510, " Hot
Particle Contamination Control," Revision 3 was reevaluated ~ but not changed; however, the procedure was changed to instruct health physics technicians to maintain a hot particle log for trending purposes and for identifying hot particle zones.
The event was discussed again with radiation workers just prior to
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outage work involving the steam generator bowl.
The event was discussed with radiation workers during initial and annual
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radiation worker training.
A video involving the use of communication equipment in contaminated
areas within the radiological controlled area was produced and shown to radiation workers.
All of the licensee's proposed corrective actions had not been addressed prior to this inspection.
The radiation work permit used for steam generator bowl draining activities had not been revised to include specific information-to
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reduce the possibility of hot particle generation or spread.
A Performance.
Improvement Request involving this item was initiated and appropriate corrective actions were made before the end of the inspection.
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ATTACHMENT 1 PERSONS CONTACTED
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1.1 Licen, Personnel i
T. A. Conley, Health Physics Support Supervisor
- R. A. Hammond, Health Physicist
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- E. C. Holman, ALARA Coordinator
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- L. M. Kline, Health Physics Operations Supervisor J. D. Lutz, Licensing Engineer
- 0. L. Maynard, Director, Plant Operations
- R. Meister, Senior Engineering Specialist
- T. S. Morrill, Manager, Radiation Protection
- W. B. Norton, Manager, Technical Support
- F. T. Rhodes, Vice President, Engineering
- T. L. Riley, Supervisor, Regulatory Compliance
- S. Wideman, Supervisor, Licensing 1.2 NRC Personnel
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- G. A. Pick, Senior Resident Inspector-
- Denotes personnel that attended the exit meeting.
In addition to the personnel listed, the inspector con',. acted other personnel during this inspection period.
2 EXIT MEETING An exit meeting was conducted on July 2, 1993.
During this meeting, the inspector reviewed the inspection scope and findings of the report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector.
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