IR 05000482/1997015
| ML20198K435 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/22/1997 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198K433 | List: |
| References | |
| 50-482-97-15, NUDOCS 9710240027 | |
| Download: ML20198K435 (15) | |
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EEC1QSURE 1
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U.S. NUCLEAR REGULATORY COMMISSION
- . REGION IV
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. Docket No.: 50-482
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License No.: NPF-42 Report No.: 50 482/97-15
, Licenses: Wolf Creek Nuclear Operating Corporation
. Facility: . Wolf Creek Generating Station-j Location: 1550 Oxen Lane, NE p . Burlington, Kansas Dates: September 22-25,1997
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l- Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist
! Plant Support Branch
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- Accompanying Brad A. Smalldridge, Resident inspecto Personnel
- Wolf Creek Generating Station
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Approved By: Blaine Murray, Chief, Plant Support Branch i Division of Reactor Safety
- - Attachment: Supplemental Inspection Information
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EXECUTIVE SUMMARY Wolf Creek Generating Station NRC inspection Report 50-482/97 15 This announced, routine inspection reviewed the implementation of the radiological environmental monitoring program and the meterological monitoring program. Training and qualifications, quality assurance oversight, f acilities and equipment, and annual reports were also reviewe filnLSMpport
Overall, excellent radiological environmental and meterological monitoring programs were implemented. Environmental sampling locations were properly established and met Offsite Dose Calculation Manual requirements. Environmental sampling equipment was calibrated and properly maintained. Appropriate changes were made to the environmental sample locations described in the Offsite Dose Calculation Manual as a result of the current land use census. Good radiological environmental monitoring implementing procedures were maintained. The meteorological tower instrumentation was properly maintained and calibrated (Sections R1.1, R1.2, R2.1, R2.2, and R3.1).
- An experienced, trained, and quakfied staff was maintained. The knowledge and performance of the environmental management and technical staff were excellent (Sections R4, RS, and R7.1).
- A comprehensive audit of the radiological environmental monitoring program was performed. Timely corrective actions were implemented. Qualified auditors, who were assisted by experienced and knowledgeable technical specialists from other nuclear power f acilities, performed the audit. There was an appropriate evaluation performed of the vendor environmentallaboratory's performance. The lack of an independent or " third party" evaluation of the thermoluminscent dosimeter was considered a weakness (Sections R7.1 and R7.2).
- A noncited violation was identified for the f ailure to maintain proper wind direction instrument set points that met accuracy requirements (Section R8.1).
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3-Report Details
--Summarv of Plant Statua The plant was at power operations during the week of the inspection. There were no events during this inspection that adversely affected the inspection result IV. Plant Suppo R1 Radiological Protection and Chemistry Controls R Radiolooical Environmental Monitorina Procram insoection' Scone (84750) _
The radiological environmental monitoring program was reviewed to determine compliance with the requirements in the Offsite Dose Calculation Manual. Selected environmental media sampling stations were inspected. ' An environmental technician was observed collecting samples of air particulate filters and iodine charcoal cartridge Observations and Findinas Sample collections and analyses were performed at the required frequencies specified in the_Offsite Dose Calculation Manual. Sample shipment logs were completed in accordance with approved procedures. The inspectors verified that the environmental sample locations met the Offsite Dose Calculation Manual requirements. Minor changes had been made to several environmental sample locations descriptions in the Offsite Dose Calculation Manual, based on the current annual land use census. Annual Radiological Environmental Operating Reports were submitted to_the NRC, .
1 Conclusions l
! Overall, an excellent radiological environmental monitoring program ;
I was implemented in accordance with the Offsite Dose Calculation Manual. All i- required environmental sampling and analysis activities were performed.
! Environmental sampling locations were properly established and met Offsite Dose
- . Calculation Manual requirements.
, . R1.2- Meteoroloaical Monitorina Proaram
! Insoection Scoce (847501
l The meteorological monitoring program was reviewed to determine agreement with l- the recommendations in NRC Regulatcry Guide 1.23 and compliance with the
- commitments in Updated Safety Analysis Report, Section 2.3, and Technical
[ Specification 3/4.3.3.4. The meteorological tower and monitoring instrumentation
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-4 Qbservations and Findinos Meteorolog cal monitoring instrumentation including sensing, recording, and transmitting equipment was operational, calibrated, and properly maintained. The
! meteorological tower's monitoring instrumentation provided the required instrument
- channels. The required daily channel checks, physicalinspections, and semi annual
calibrations were performed on the meteorologicalinstruments.
i The inspectors observed instrument and control technicians perform the semi-annual calibration of the meteorological tower wind speed instruments positioned at the 10-l and 60-meter levels. The resident inspector accompanied an instrument and control
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technician to the 60-meter level of the meteorolori.' tower and observed the inspection of the wind sensing instrumentation, c, Conclusions An excellent meteorcfogical monitoring program was implemented. The meteorological monitoring program satisfied the commitments of Updated Safety Analysis Report and met Technical Specification requirement R2 Status of Radiological Protection and Chemistry Facilities and Equipment
- R Environmental Monitorina Eauioment
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4 Insoection Scoce (84750)
Selected environmental sampling stations were inspected to verify that the stations
were properly maintained and that all sampling c<1uipment was operable and calibrated. Sample preparation and storage f acilities were inspected to verify that sufficicut supplies and spare equipment were available.
- Observations and Findinas The environmental media sample preparation / storage area was equipped with the l .necessary supplies and spare equipment to perform the required radiological environmental monitoring prograri. sampling activitie The inspectors toured the following types of sampling ths with an environmental technician
- air particulate, vegetation, thermoluminescent dosimeter, groundwater, and surface water. The inspectors noted that the air sampling equipment in use was operational and properly calibrated. A timing device was used with each air sampler to monitor its time of operation and account for any power outages. Environmental samples were shipped to a vendor laboratory for analysi The inspectors obi.erved that all thermoluminescent dosimeters were currently placed inside plastic thermostat boxes mounted to utility poles. This was a
, corrective actic, to a previous inspection concern where it was observed that some thermoluminescent dosimeters were placed in housings made of different materials.
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5- Conclusions Sufficient supplies and spare environmental sampling equipment were available and properly maintained. Environmental monitoring stations were properly maintained, and the sampling equipment was operable.
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R2.2 Meteoroloaical Monitorino Eauioment insoection Scooe (84750)
L The inspectors inspected the meteorologicalinstrumentation at the meteorological tower and reviewed the associated instrument calibration records to ensure that the remote meteorological instrumentation on the tower was operable, calibrated, and properly maintained, Observations and Findinas The meteorological towe and monitoring instrumentation at the 10 , 35 , 60 , and d
85-meter levels were prog erly maintained. The meteorological tower was equipped
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with wind speed, wind ditection, and temperature sensing instrumentation, which met Technical Specificati>n requirements. During 1996, the meteorological data recovery rate was greate than 90 percen The inspectors verified that the meteorological instrumentation was as described in the Updated Safety Analysis Report. The instrumentation was operable and properly calibrated. New data recorders had been installed since the previous NRC inspection conducted in July 1996. Daily channel checks and semi-annual calibrations of the meteorological instrumentation were performed in accordance with Technical Specification requirements, Conclusions The meteorological monitoring instrumentation channels were operational and properly calibrated at the required frequenc R3 Procedures and Documentation R3.1 Chanaes in the Offsite Dose Calculations Manual and Radioloaical Environmental Monitorina Imolementina Procedures Insoection Scoce (84750)
Changes to the Offsite Dose Calculation Manual regarding the radiological environmental monitoring program were reviewed. Radiological environmental monitoring program implementing procedures were reviewe !
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6- Observations and Findinns The current Offsite Dose Calculation Manual AP 078-003, Revision 0, February 12, 1996, was written in the new format. On-the spot changes had been made to the Offsite Dose Calculation Manual since the last inspection. These changes:
(1) established a new thermoluminescent dosimeter station in the 0-3 mile range in the sector south of the plant as corrective action in response to Performance improvement Request 97 1709,(2) clarified ground water and milk sample collection requirements, (3) changed the location of the nearest resident to the plant, and (4) chang > ' the locations of the nearest gardens producing broadleaf vegetation. The in' setors noted that the 1996 annualland use census showed that milk was not ,_ duced for human consumption within 5 miles of the site and that the previously sampled control milk location was no longer producing mil The radiological environmental monitoring program implementing procedures described the responsibilities and requirements for collection, documentation, and s. pment of environmental media samples collected around the site. The procedures were written with sufficient detail to effectively conduct the recuired radiological environmental monitoring program activities, c, . Conclusions On-the spot changes to the radiological environmental monitoring program were appropriately made in the Offsite Dose Calculation Manual and the procedures implementing the radiological environmental monitoring program. Good radiological environmental monitoring implementing procedures with sufficient detail were maintaine R3.2 Annual Reoorts insoection Scoce (84750)
The 1996 Annual Radiological Environmental Operating Report and the 1996 Annual Radioactive Effluent Release Report were reviewed to determine compliance with the requirements of Technical Specifications 6.9.1.6 and 6.9.1.7 and the Offsite Dose Calculation Manua These reports were reviewed relative to the radiological environmental monitoring program for data omissions, obvious mistakes, anomalous measurements, observed biases, trends in the data, and interlaboratory analyses comparisons, Observations and Findinas
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Sample data in the 1996 Annual Radiological Environmental Operating Report demonstrated that the required sampling, analyses, and reporting requirements were met. Program discrepancies and missed samples were reported. The 1996 annual land use census was conducted, and the results were documented in the Annual Radiological Environmental Operating Report. The results of the vendor environmentallaboratory's participation in an interlaboratory comparison program
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- were reported. All analytical results were within three standard deviations of the
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- known certified results.
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{ Excellent Annual Radiological Environmental Operating and Radioactive Effluent i Release Reports were submitted in a timely manner and contained the required y inforrration.
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l R Staff Knowledge and Performance-
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l Environmental management group personnel were observed and interviewed to j determine their knowledge of the environmental sampling requirements and
! implementing procedures.
l j- . Observations and Findinos i
j' The inspectors noted that good radiological and sample handling practices were L used by the environmental technician to maintain sample integrity. Sampling and
, sample shipment preparation activities observed were conducted in accordance with s approved procedures.
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l -The knowledge and performance of personnel responsible for implementin0 the environmental monitoring program were excellent.
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l R5 Staff Training and Qualification
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, Insoection Scone (84750) ;
! The training and qualification programs for the technical staff responsible for implementing the radiological environmental monitoring program were reviewed.
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Discussions concerning staff training were conducted with an environmental
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technician responsible for implementing the radiological environmental monitoring -
program, t Observations and Findings f
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< Changes to implementing procedures were included as required reading for the
- environmental technical staff. The inspectors determined that proper training and I _
qualification programs had been implemented. The inspectors did not find any j concerns with the training records reviewe Conclusion f Trained, experienced, and qualified personnel implemented the radiological environmental monitoring program.
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. R6 Organization and Administration insoectier Scone (84750)
The orgarization, staffing, and assignment of the radiological environmental monitoring program responsibilities were reviewe Observations and Findinas The environmental management group within the resource protection department was responsible for implementing the radiological environmental monitoring progra The inspectors reviewed organizational charts which identified the staff and position There were no changes in the organization or staffing of the environmental management group since the previous NRC inspection of this area in July 1996, Conclusion The environmental management group maintained a stable and adequate staf R7 Quality Assurance Program R Radioloaical Environmental Monitorina Quality Assuranca.Proaram a, lasoection Scoce (84750)
The following items were reviewed:
- Qualifications and resumes of auditors and technical specialists
- 1997 annual quality assurance audit plan and audit report
- Quality biennial audit schedule Observations and Findinas The annual quality assurance audit of the radiological environmental monitoring program was comprehensive ar i provided management with good oversight of the radiological environmental monitoring program. Two findings were identified during the audit. The licensee used the performance improvement request system for tracking and trending of identified items and implementation of corrective action The two performance improvement requests were closed promptly with the completion of appropriate corrective action The inspectors determined that the quality assurance auditors and technical specialists who performed the audit had appropriate knowledge and experience, which enabled them to properly assess performance and implementation of the radiological environmental monitoring program. The audit team consisted of licensee personnel and two technical specialists from other nuclear power plant _____-_ _ _ _ _ _ _ .-__ - _ - -
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9 Conclusmns A very good, comprehensive audit was performed which effectively evaluated the performance and implementation of the radiological environmental monitoring program. Qualified auditors, who were assisted by experienced and knowledgeable technical specialists from other nuclear power f acilities, performed the audi R7.2 Quality Assurance Pragram for Vendors Insoection Scoce (84750)
The quality assurance vendor audit program of vendors performing surveillance activities involving the radiological environmental monitoring program was reviewe Observations and Findinas The licensee used an off site vendor environmental laboratory to perform required l radiochemistry analyses of environmental media samples and another power reactor l licensee to process the environmental thermoluminescent dosimeters, i
The licensee used a nuclear procurement issues committee audit of the vendor environmentallaboratory to evaluate the laboratory's analytical performance. The audit was comprehensive and satisf actory to evaluate the laboratory's ability to perform the Offsite Dose Calculation Manual required analyse The inspectors noted that the licensee had not performed an independent " suppliers" audit nor had evaluated a " third party" audit of the thermoluminescent dosimeter program of the Utilities Services Alliance's nuclear licensed utility member who was processing the environmental thermoluminescent dosimeters for the licensee and other NRC licensee members of the alliance. Also, the licensee had not reviewed an audit of the thermoluminescent dosimeter processing program performed by the
supplict licensee's" quality assurance program. Administrative Procedure AP 24-002, " Requisition and Procurement Process," Revision 4, states in paragraph 6.13.3 that licensed utilities will not normally be listed on the suppliers information list. Therefore, licensed utilities not listed on the suppliers information list are not required to be audited and evaluated to verify that their qualifications as a supplier of goods and services are maintained. The inspectors concluded the licensee's lack of an independent evaluation of the supplier's thermoluminescent dosimeter processing program prior to procurement of analytical services was a weakness in the licensee's program to qualify another nuclear licensed utility who furnished purchased analytical services. This vendor audit issue was discussed with the licensee during the inspection and at the exit meeting conducted on September 25, 1997, in response to the inspectors' observation, the licensee wrote Performance Improvement Request 97-2912 to evaluate their method to qualify other nuclear licensed utilities who furnish services. The inspectors determined that their was no violation of regulatory requirements, e
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There was an appropriate evaluation of the vendor environmentallaboratory's performance. The lack of an independent or " third party" evaluation of the nuclear licensed utility's thermoluminscent dusimeter processing program used to process the environmental thermoluminscent dosimeters was considered a weaknes .
R7.3 Performance Imorovement Reauests and Corrective Actions Insoection Scoce (84750)
Selected performance improvement requests to evaluate the effectiveness of the licensee's controls in identifying, resolving, and preventing problems in the radiological environmental monitoring program and the meteorological monitoring program were reviewed, Observations and Findinas Performance improvement requests issued in 1996 and'1997 in the area of radiological environmental monitoring and meteorological monitoring revealed that licensee personnel used this reporting system as needed and had a proper threshold for identifying problems. Performance improvement requests were initiated for most problems encountered during the implementation of the radiological environmental monitoring program and were also used to track and trend audit results. In general, responses to the reviewed performance improvement requests were timely and included proper corrective actions, Conclusion Good performance was noted in identifying problems, performing evaluations, and implementing corrective actions in a timely manne R8 Miscellaneous Radiological Protection and Chemistry issues R8,1- (Closed) Licensee Event Reoort 97-006: Failure to Comolv with Technical Soecification 3.3. Licensee Event Report 97-006 documented the identification of nonconservative setpoints (iS.4 degrees) for the 10 and 60-meter wind direction instruments which did not meet the instrument accuracy requirements of iS.O degrees in Regulatory Guide 1.23. The bases for Technical Specification 3.3.3.4 for the operability of the meteorologicalinstrumentation required that the program implement the recommendations of Regulatory Guide 1.23. This problem was identified on April 14,1997, during the review of a setpoint change reqv. t for the installation of new chart recorders for the meteorological instruments. The inspectors verified that no similar problems were identified and that the corrective actions described in the licensee event report were implemented. Procedures are now in place to ensure that
.when design documents affecting setpoints are revised, effected procedures are revised accordingly. A sampling of the data in the Wolf Creek Results Engineering Document WCRE-01, " Total Plant Setpoint Document," is currently being performed
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-11-to detetmine if the information is correct. This corrective action is being tracked by Performance improvement Request 97-1120 and is due to be completed by December 31,1997. The f ailure to establish proper instrument accuracy setpoints for the 10 meter and 60 meter wind direction instruments and provide proper instrument operability criteria are a violation of Technical Specification 3.3. Therefore, this non repetitive licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50 482/9715-01).
R8.2 (Ocen) Insoection Followuo item 9617-01: Evaluation and Validation of Meteoroloaical Monitorina Data This item was discussed in NRC Inspection Report 50-482/96-17 and involved the inspectors' concer: Mth the lack of proper validation of meteorological data. The recently assigned meteorological tower design engineer was not trained to properly evaluate and validate the meteorological data. No instructions or validation criteria had been developed to provide the frequency and methods to accurately validate the meteorological data. Typically, a meteorologist or a meteorological expert is responsible for interpreting and evaluating all meteorological tower data. The licensee had previously relied on the plant computer's radiological release information system to monitor and validate the meteorological data. However,in 1990, the radiological release information system was replaced with the nuclear plant information system. The ccmputer program that was used for meteorological data verification and validation, that was formerly in the radiological release information system, was not subsequently included in the nuclear plant information system. The licensee reviewed the Updated Sefety Analysis Report Table 2.3 29b,
" Data Recovery Statistics," for March 1980 to March 1981, and the semiannual and Annual Radioactive Effluent Release Fwports from July 1985 to Decemoer 1990 to assure that the meteorological data recovery percentage was greater than 90 percent. The 1995 and 1996 equipment out of service Icgs, Technical Specification surveillance tests, and computer down time were used to generate accurate meteorological data in the 1996 Annual Radioactive Effluent Release Report. The licensee is currently working with a contractor to generate validation criteria equations which can be programed into the nuclear plant information system computer to verify and validate meteorological tower instrument data. This inspection followup item will remain open pending she implementation of an accurate method of verifying and validating meteorological tower instrument dat V. Management Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting conducted on September 25,1997. The licensee acknowledged the findings presented. No proprietary information was identifie . .- .
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L ATTACHMENI i
i EUPPLEMENTAL INFORM ATION
PARTIAL LIST OF PERSONS CONTACTED 1' Licensee i
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C. Warren, Chief Operating Officer M. Blow, Manager, Chemistry and Radiation Protection a R. Butz, System Engineer, Radiation Monitors
- V. Canales, Supervisor, Suppliers / Materials Quality, Purchasing and Material Services 4- P. De-Blonk, Supervisor, Instruments and Control R. Denton, Quality Specialist, Quality Evaluations
- J. Harris, Supervisor, Radiation Protection I D. Humlicek, Technician 111, Instruments and Control L T. Krause, Quality Specialist, Supplier Quality
- S. Koenig, Supervisor, Quality Evaluations - Surveillances B. Loveless, Superintendent, Resource Protection
! M. McMullen, Senior Engineer, Design Engineering j- D. Moore, M *ager, Maintenance
- W. Norton, Manager, Performance improvenent and Assessment
- E. Peterson, Supervisor, Quality Evaluations - Audits
- T. Rawlings, Technician, Environmental Management
- C. Reekie, Engineering Specialist, Regulatory Compliance
. L. Ratzlaff, Supervisor Engineer, System Engineering
< E. Schmotz 'r, Manager, Purchasing and Material Services
! H. Stubby, dupervisor, Technical Training -
i J. Weeks, Me'ager, Emergency Planning D. Williamson, Supervisor, Environmental Management l
- C. .Younie, Manager, Operations i
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NRC l F. Ringwald, Senior Resident inspector, Wolf Creek B, Smalldridge, Resident inspector, Wolf Creek i D. Passehl, Senior Resident inspector, Callaway
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LIST OF INSPECTION PROCEDURES USED IP 84750 Radioactive Waste Treatment, and Ef fluent and EnvironmentalMonitoring
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- L{ST OF ITEMS OPENED CLOSED. AND DISCUSSED l'
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50-482/9715 01 NCV Failure to satisfy accuracy requirements for wind direction instruments Closed 50-482/9715-01 NCV Failure to satisfy accuracy requirements for wind direction instruments Cl21std 50-482/9715-01 LE Failure to satisfy accuracy requirements for wind direction instruments Discussed 50-482/9617-01 IFl Evaluation and Validation of Meteorological Monitoring .
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Data LIST OF DOCUMENTS REVIEWED l
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I ORGANIZATION CHART Resource Protection Organization Chart - August 1997 QUALITY ASSURANCE DOCUMENTS -
AP 20A-003, " Audit / Surveillance Scheduling," Revision 2 AP 20A-004, " Audit Procedure," Revision 3 Quality Biennial Audit Schedule, Revision 13 Quality Assurance Audits Quality Audit Report K 477, " Environmental Management (REMP/ODCM/EEMP)," July _18, 1997-l Mendor Audit NUPIC Joint' Audit 97-002, Teledyne Brown Engineering Environmental Services, performed April 22-25,1997
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PROCEDURES-I
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ADM 08-807, "l&C Group Surveillance Testing," Revision 10
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[- At 078-001, " Radiological Environmental Monitoring' Program Administration," Revision'1- .
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At 078 002, " Review of Radiological Environmental Laboratory Analysis," Rev_ision-2 i
Al 078-003, " Interpreting Results of Radiologicel Environmental Sample Analysis,"
Revision 1-k ' Al 078-004, " Reporting of Radiological Environmental Monitoring Program Results,"
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~A l 078 005, " Radiological Environmental Monitoring Program implementation," Revision 5 At 07B'-006, " Collection, Preparation and Shipment of Fish Samples," Revision 2
- Al 078 007, " Collection, Preparation and Shipment of Meat and Poultry Samples,"~
f- Revision 1 1 Al 078-008, Collection, Preparation and Shipment of Aquatic Plant Samples," Revision 1
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1-h Al 07B 009, " Collection, Preparation and Shipment of Sediment Samples," Revision 1
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Al 078-010, " Collection of Direct Radiation Samplers,". Revision 1
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Al 078-011, " Collection, Preparation and Shipment of Water Samples," Revision 1 -
- At 078 012, " Collection, Preparation'and Shipment of Fruit and Vegetable Samplos,"
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Revision 1-At 078 015, " Population / Land Use Survey," Revision 1-
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AI 078-016,' " Radiological Environmental Monitoring Equipment Control and Calibration "
LRevision 2-Al 078-017, ." Calibration and Maintenance of Ai. Sampler Pumps," Revision 1
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Surveillance Tests STS CR-001, "Shitt Log for Modes 1, 2, & 3," Revision 35 STS IC 890A, " Channel Calibration of Wind Speed Meteorological Instrumentation,"
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Revision 8 STS IC 8908, " Channel Calibration of Wind Direction MeteorologicalInstrumentation,"
Revision 8 STS IC 890C, " Channel Calibration of 60M/10M Differential Temperature Instrumentation,"
Revision 8
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REPORTS Annual Radiological Environmental Opereting Report - 1996 Annual Radioactive Effluent Release Report - 1996 i
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MISCELLANEOUS DOCUMENTS
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Summary of environmental and meteorological performance improvement requests written since January 1996 Environmental management group training records
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