IR 05000482/1993031

Insp Rept 50-482/93-31 on 931115-19.No Violations Noted. Major Areas Inspected:Radiation Protection Program,Including Audits & Appraisals,Training & Qualifications,External & Internal Exposure Controls,Radioactive Material Control

ML20058J833
Person / Time
Site:	Wolf Creek
Issue date:	12/03/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058J817	List: IR 05000482/1993031 ML20058J815
References
50-482-93-31, NUDOCS 9312140260
Download: ML20058J833 (9)

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION REGION IV  :

Inspection Report: 50-482/93-31 License: NPF-42 Licensee: Wolf Creek Nuclear Operating Corporation P.O. Box 411 -

Burlington, Kansas i Facility Name: Wolf Creek Generating Station Inspection At: Burlington, Kansas Inspection Conducted: November 15-19, 1993  !

Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section Approved: @ M T. Murray, Chief, Facili ies Inspection

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Date Programs Section Inspection Summary Areas Inspected: Routine, announced inspection of the radiation protection program, including audits and appraisals, training and qualifications, external exposure controls, internal exposure controls, controls of .

radioactive material and contamination, program for maintaining radiation '

exposures as low as reasonably achievable (ALARA), implementation of the solid radioactive waste program, and shipping of low-level wastes for disposal, and :

transportatio !

Results: .

• The radiation protection department used the plant's Performance Improvement R2 quest Program to document the radiological !

occurrences. This program provided an effective means to identify ;

and track radiological occurrence events (Section 2.1). j

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• Personnel turnover in the radiation protection department was very low (Section 2.2).

• The corporate organization no longer provided support to the site ;

radiation protection organization. No decreases in program effectiveness were noted as a result of this change (Section 2.2).

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9312140260 931200 PDR ADDCK O*000482 G PDR  :

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• New senior radiation protection technicians met qualification :

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requirements (Section 2.3).

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• The licensee continued to support the professional development of radiation protection technicians (Section 2.3). l

• A good training program for supervisors and professionals in the :

radiation protection organization was maintained (Section 2.3). <

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• Qualified instructors provided training for radiation protection -

technicians and radiation workers (Section 2.3).

• Internal dose calculation procedures in accordance with the new 10 CFR Part 20 needed some additional guidance but were basically ready for implementation on January 1,1994 (Section 2.5).

• A high number of the personnel skin contaminations were caused by '

hot particles. Only a small number of these eventually resulted in i radiation doses to the skin greater than 100 millirems. Overall, :

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the licensee had a good program of controlling personnel contamination (Section 2.6).

• The ALARA suggestion program received good support (Section 2.7).

• To make ALARA goals more challenging, licensee management approved a 5-year plan which, if achieved, will place the facility within the upper quartile in performance (Section 2.7).

• A good quality assurance audit was performed of solid waste and transportation activities. The audit included a technical expert from another operating facility (Section 3.1).

• Excellent programs of solid waste management and transportation of radioactive material were implemented (Sections 3.4 and 3.5).

• One of the licensee's waste shipments was involved in an accident in October 1993. The.. was no loss of material or danger to the public, as a result (Section 3.5).

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I MANT STATUS During the inspection, the plant was operating at 98 percent powe f

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2 OCCUPATION RADIATION EXPOSURE CONTROL (83750)

The licensee's program was inspected to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with ;

the commitments of Chapter 12 of the Final Safety Analysis Repor '

2.1 AUDITS AND APPRAISALS I

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No additional audits had been performed of the radiation protection program since that reviewed during NRC Inspection 50-482/93-17. An audit of the Process Control Program is discussed in Section The radiological occurrence reporting system was discontinued at the end of !

September 1993. All radiological occurrence reports had been closed by the ;

time of the inspection. The corrective action document in use was the Performance Improvement Request. The system was used by all departments on j site, and it included a means of screening, prioritizing, reviewing, and +

trending the items. After initial screening, the Performance Improvement :

Requests were sent to the responsible managers for action. If a Performance :'

Improvement Request met the criteria necessary to be classified as

"significant," a root cause analysis was performed. Corrective actions were '

documented. The Performance Improvement Request system was reviewed and I discussed in-depth in NRC Inspection Report 50-482/93-2 The inspector noted that Performance Improvement Request 93-1318, dealing with the uncontrolled release of a contaminated bucket, was originally determined by the screening group not to be significant. Radiation protection personnel were on the distribution list for the document and identified that the circumstances surrounding this item met the criteria necessary to be considered significant. They initiated another Performance Improvement .

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Request (93-1373) to document the misclassification. The inspector interpreted this to mean that the system had sufficient internal checks and i balances to ensure the proper review of radiological occurrence The inspector did not identify problems with Performance Improvement Requests assigned to the radiation protection department for actio .2 CHANGES i There were no major changes in organization, personnel, programs, or procedure l Turnover in the radiation protection department was very low. The department 3 lost the service of one technician. Another transferred to the quality assurance organizatio <

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The corporate organization no longer provided support to the site ;

organization. Personnel at the site handled contractual matters, such as with >

waste processing vendor Long range ALARA goals were overseen by site personne :

2.3 TRAINING AND QUALIFICATIONS OF PERSONNEL The inspector reviewed the qualifications of individuals who joined the radiation protection staff since the last inspection. Two individuals were promoted to senior technician status. Through reviews of the resumes, the '

inspector determined that the two met the licensee's requirement of 3 years of i experience as a radiation protection technicia l

The inspector determined that 15 technicians were registered by the National Registry of Radiological Technologists. Additionally, there were three people :

registered in training and two others in safety engineering and quality assurance. The licensee encouraged the professional development of technicians by paying for the examination and presenting training to prepare for i .

The licensee had a good program of training for supervisors and professional staff members. Training included attendance of professional meetings and ,

symposiums and visf+c to other power reactor sites to observe operations or )

conduct peer assessment ;

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There were no changes in the staffing of the trainir.g organization. Staffing was determined previously to be sufficient; instructors were qualifie .

Resources utilized by the instructors were goo !

During a previous inspection, it was noted that instructors in the corporate training group did not receive copies of radiological occurrence reports which would have been appropriate for inclusion in general employee or radiation worker training. Instructors stated that they were now on the distribution list for this type of infor.r.atio .4 EXTERNAL EXPOSURE CONTROL By direct observation while in the radiological controlled area, the inspector i determined that personal dosimetry was used in accordance with the licensee's !

requirements for monitoring external exposur The inspector also observed area posting and conducted independent radiation measurements and identified no problem l

2.5 INTERNAL EXPOSURE CONTROL The inspector reviewed the licensee's draft procedure for internal dose calculation which will be put in use when the new 10 CFR Part 20 is implemented on Ja.:uary 1,1994. The inspector proposed hypothetical internal exposure situations to licensee personnel, and it was determined that additional precautions would be helpful to remind personnel performing the '

calculations to chose the correct table of values, depending on whether the

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internal exposure was the result of inhalation or ingestion. Other than this, l the procedure was determined to provide good guidanc l I

In 1993, the licensee has not identified any internal exposures above its administrative, investigational limit.

2.6 CONTROL OF RADI0 ACTIVE MATERIALS AND CONTAMINATION, SURVEYS, AND MONITORING In 1992, the licensee recorded 53 skin contaminations. Through the third .

quarter of 1993 (a year which included a refueling outage), the licensee recorded 123 skin contamination events. Approximately 44 percent of the skin contaminations resulted from hot particles. Approximately 16 percent of the personnel contaminations resulting from hot particles resulted in skin doses above 100 millirems. One individual received a calculated skin dose of 33.9 rems (8 microcurie hours). The event was documented in Licensee Event Report 93-006 and NRC Inspection Report 50-482/93-0 Even though a significant increase in contamination events were noted during the outage, the inspector noted that the licensee had implemented an effective program to address the events.

The licensee had a good program of documenting and trending personnel contamination evev a. The trending program provided suitable feedback to ensure that corrective actions were taken if programmatic weaknesses were identi fied.

2.7 MAINTAINING OCCUPATIONAL EXPOSURE ALARA There have been 24 ALARA suggestions submitted in 1993. All suggestions have been reviewed. No suggestion awaiting implementation was more than 2 years old. The older suggestions were either awaiting engineering review or !

implementation during the next refueling outag ,

Some of the major ALARA improvement items approved were a reactor head stand shield, reactor head 0-ring cleaning machine, and steam generator bowl drain modi fications.

The inspector reviewed the minutes of the ALARA committee meetings and the ALARA working group meetings. Attendance was generally good.

The exposure goal for 1993 is 280 person-rems. At the time of the inspection, the licensee had recorded approximately 179 person-rems. The inspector had ,

previously noted that the goal was not challenging. The licensee shared with the inspector its Long Range Exposure Reduction Pla The plan, which was approved by the chief executive officer, set forth goals which the licensee felt will place it in the upper quartile of performance of operating plant _ .. . -

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-6-Person-rem totals for the previous 5 years are as follows: j l

(1988= :1989- ?1990i ii991L s1992) -

297 14 182 308 70

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2.8 Conclusions Performance Improvement Requests sufficed to raplace radiological occurrence report <

Turnover in the radiation protection department was very lo The corporate organization no longer provided support to the site radiation protection organizatio ,

New senior radiation protection technicians met qualification requirement The licensee continued to support the professional development of radiation protection technicians. A good training program for supervisors and ;

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professionals in the radiation protection organization was maintaine Qualified instructors were used for radiation protection technician and radiation worker trainin Internal dose calculation procedures in accordance with the new 10 CFR Part 20 needed some additional guidance but were basically ready for implementation on -

January 1, 199 Approximately 44 percent of the personnel skin contaminations were caused by ,

hot particles. Only about 16 percent of those resulted in radiation doses to the skin greater than 100 millirem The ALARA suggestion program received good support. To make ALARA goals more challenging, licensee management approved a 5-year plan which, if achieved, ,

will place the facility within the upper quartile in performanc The licensee had a good program of controlling personnel contaminatio SOLID RADI0 ACTIVE WASTE MANAGEMENT AND TRANSPORTATION OF RADI0 ACTIVE MATERIALS (86750)

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3.1 Audits and Appraisals The licensee's program was inspected to determine compliance with Technical Specification 6.11, the requirements of 10 CFR Parts 20.311, 61, 71, and Department of Transportation Regulations 49 CFR Parts 171 through 178; and agreement with the commitments of Chapter 11 of the Final Safety Analysis Repor The inspector reviewed Quality Assurance Audit TE: 50140-K384, " Process ,

Control Program," performed March 1-29, 1993. The audit team included a technical expert from another operating facility with radwaste experienc ,

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-7-The audit resulted in the initiation of two Performance Improvement Request One of these was closed during the audit; the other was addressed quickly by the radioactive waste group after the completion of the audi The technical expert identified that the computer code library file contained the incorrect A2 values for Iron-59 and Niobium-94. The values were not those set by 49 CFR 173.435. Additionally, the reportable quantity of Neptunium-237-was incorrect. The licensee determined that the condition existed since March 21, 1988, at least, and initiated the first of the two Performance

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Improvement Requests. Licensee representatives determined that the mistakes in the computer code did not result in the incorrect classification of any waste shipment. The entire computer code library file was reviewed by the '

licensee, but no other problems were identified. The licensee contacted the vendor which reviewed the problem and stated that the only other facility i which was affected was that of the visiting audito .2 Chances

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The licensee had modified the existing radwaste building to provide more l interim storage area for low level radioactive waste. Licensee rapresentatives estimate the capacity of the facility to be approximately 11,700 cubic feet. They stated that this will equal 3 to 5 years of storage, depending on the exact rate of waste generation. An amendment to the Final Safety. Analysis Report regarding the modifications is pendin .3 Trainino and Qualifications The inspector reviewed training records and determined that the individuals involved with the transfer, packaging, and transport of radioactive material were provided with periodic retraining in Department of Transportation and NRC regulatory requirements as referenced in NRC Bulletin 79-1 .4 Implementation of the Solid Radioactive Waste Procram The licensee used the RADMAN computer code for classifying waste. Regular updates to the computer code were supplied by the vendor. Individuals using the code had received vendor training regarding its us The health physics supervisor in charge of the solid radioactive waste program maintained a list of waste streams and the latest sampling date for each on a bulletin board in his office. The inspector reviewed selected vendor laboratory reports and verified that the sampling dates listed were correc All active waste streams had been sampled within the required intervals. The computer code's data base was updated based on the latest sampling information. In-house analysis was also performed and compared with the results of the vendor laboratory. The licensee made necessary corrections to the data entry, when classifying waste, based on the relationship between its results and those of the vendor laborator The inspector reviewed records of waste generation and confirmed that it did not exceed the maximum projected amounts listed in the Final Safety Analysis

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-8-Repor The licensee uses vendors for processing radioactive waste to reduce the volume before burial. No compacting was performed at the sit .5 Shippino of low-level Wastes for Disposal and Transportation The licensee had made 59 radioactive material shipments thus far in 199 Thirteen of the shipments were radioactive wast The inspecter reviewed selected shipping packages and noted that detailed checklists were used in preparing shipments for transport. Manifests for the shipments were generated by the computer code. The packages included copies l of information presented to the drivers of the vehicles and emergency phone j numbers and backup phone number The licensee maintained current copies of Department of Transportation and NRC regulations. A vendor provided periodic updates of the regulations to the l l

license l One of the licensee's shipments of dry, activated waste was involved in an j accident in Ada County, Idaho, on October 10, 1993. The waste was being

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shipped to a processor via a commercial trucking line. The waste containers were not damaged in the accident, and the public was not at ris .6 Conclusions A good quality assurance audit was performed of solid waste and transportation activitie Excellent programs of solid waste management and transportation of radioactive material were implemente )

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ATTACHMENT I PERSONS CONTACTED 1.1 Licensee Personnel

• A. Blow, Health Physicist

• L. F. Breshears, Health Physicist

• S. C. Burkdoll, Supervising Instructor, Health Physics T. A. Conley, Health Physics Support Supervisor

• R. A. Hammond, Health Physicist

• E. C. Holman, ALARA Coordinator L. M. Kline, Health Physics Operations Supervisor

• 0. L. Maynard, Vice President, Plant Operations C. M. Medency, Radwaste Supervisor

• R. A. Meister, Senior Engineering Specialist, Regulatory Compliance

• T. S. Morrill, Manager, Radiation Protection T. G. Moreau, Supervising Instructor, General Employee-Training

• F. T. Rhodes, Vice President, Engineering

• T. L. Riley, Supervisor, Regulatory Compliance

• S. Wideman, Supervisor, Licensing 1.2 NRC Personnel

• A. Pick, Senior Resident Inspector

• J. F. Ringwald, Resident Inspector

• Denotes personnel that attended the exit meetin In addition to the personnel listed, the inspector contacted other personnel during thi inspection perio EXIT MEETING

An exit meeting was conducted on November 19, 1993. During this meeting, the :

inspector reviewed the scope and findings of the report. The licensee did not express a position on the inspection findings documented in this report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspecto .

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