IR 05000482/1997020
| ML20199H446 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/14/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199F693 | List: |
| References | |
| 50-482-97-20, NUDOCS 9711260120 | |
| Download: ML20199H446 (12) | |
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ENCLOSUPIL
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U.S. NUCLEAR REGULATORY COMMISSION
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. REGION IV.
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Docket No.:-
50-482
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License No.: 4-NPF-42
' Report No.:
50-482/97 20 Licensee:
Wolf _ Creek Nuclear Operating Corporation Facility:
Wolf Creek Generating Station Location:-
1550 Oxen Lane, NE Burlington, Kansas Dates:
October 20-24, 1997 Inspector:
L. T. Ricketson, P.E., Senior Raoiation Specialist
- Plant Support Branch Approved By:
Blaine Murray, Chief Plant Support Bconch Division of Reactor Safety ATTACHMENT:
Suppleniental Information g
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DECUTIVE SUMMARY Wolf C:eek Generaung Station NRC Inspection Report 50-482/97 20
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This announced, routine _ inspection reviewed planning and preparation, external exposure controls, internal exposure controls, control of radioactive material and contamination, procedures and documentation, and training and qualifications.
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Plant Suoport
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Preparation for outage activities by the radiation protection organization was
satisfactory. Although radiation work permit package preparation was good, generally,' abort criteria were not included in all packages in which it was
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- appropriate. Prejob briefings needed improvement, because requirements were not D
clearly stated and current survey information was not always used. Shift turnover meetings were conducted well.- The radiation protection staff was supplemented.
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appropriately by contract' radiation protection personnel _(Section R1.1).
External exposure controls were implemented properly, in most cases. Job coverage
by radiation protection personnel was good. The response and followup by radiation protection personnel to an emergency situation in the radiological controlled area were excellent (Section R1.2).
A violation was identified for the f ailure to properly post and control a high radiation
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area with a dose rate greater than 1000 millirems per hour (Section R1.2).
Internal exposure controls were implemented appropriately (Section R1.3).
- Radiologi.:al werker practices were satisft; tory. _ Better p*ocedural guidance was i
needed with respect to the control and release of radioactive materials (Section 81.4).
A violation was identified, because accountability was not properly maintained when
radioactive material was condit;onally released from the radiological controlled area (Section R1.t-).
A violation was identified, because posting in a contaminated area around the spent
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fuel poo'. was not conspicuous (Section R1.4).
._The radiation protection manager and the contract radiation protection technicians
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met qur.lification requirements (Section RS).
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3-Reoort Details Plant Status Refueling Outage 9 began October 4,1997. The outage was originally planned for 35 days. During the inspecti9n, the licensee experienced problems with the refueling machine and subsequent delays in the outage schedule.
LV. Plant Suncort R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 Plannino and Prenaration a.
Insoection Scoce (8375Q1 The inspector interviewed radiation protection personnel and reviewed the following:
ALARA goals
Outage scheduling
ALARA prejob reviews
Prejob briefings / meetings
Turnover meetings
Supplies and consumables
Supplemantal staffing
b.
Observations and Findinos During reactor shutdown, following the addition of hydrogen peroxide, a smaller percentage of soluble radionuclides than usual was identified in the reactor coolant.
Additional injections of hydrogen peroxide to increase the soluable radionuclides were ineffective. In an effort to mitigate the effects of plateout on reactor piping and components, the licensee ran the reactor coolant pumps an additional 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />, maintaining circulation and removing additional radioisotopes. This action delayed outage activities but indicated good management support for the ALARA concept.
Despite the licensee's efforts, dose rates in some areas inside the bioshield were 1.5 to 1.8 times higher than measured during the previous outage. Licensee representatives stated that the percentage of soluble radionuclides in the reactor coolant could have been affected by an axial power offset in the core. Licerisee -
representatives also stated that they felt the dose rates would have been even higher if they had not run the reactor coolant pumps longer than originally planned.
The ALARA exposure goal for the outage was 140 person-rems. The total of all the radiation work permit dose projections was 157 person-rems. Licensee representatives acknowledged that the goal probably would not be met because of the increased dose rates, unlesa the scope of the outage work was reduced. By October 23,1997, the licensee had accrued 83 person-rems and had not begun
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work on the. steam generators. The inspector concluded that the ALARA exposure goal was very challenging and probably no longer realistic.
The inspector noted that jobs such as installation of nozzle dams in steam generators and pulling one of the reactor coolant pump impellers were scheduled in be performed at the same time. If that occurred, the area would be very congested, and the situation could potentially add to the total dose accrued. Therefore, the inspector concluded that scheduling and sequencing of outage activities were not
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optimums. The licensee acknowledged the inspector's comment and added that they were working to improve this area of the program.
Radiation work permit packages generally indicated adequate preparation for work activities. Most activities had been performed during previous refueling outages, and radiation surveys and lessons learned from previous years were included in the background information. The latest radiation surveys were not always in the package because of the lag time resulting from the supervisory review process.
However, copies of the surveys were available in a separate binder. Discussions of abort criteria were not included in some radiation work permit packages in which it was appropriate. An example of this was Radiation Work Permit 97 6062, Re*.ision 4, a radiation work permit for removal of the inner mast of the refueling machine.
The inspector attended various prejob briefings. During the format prejob briefing for Radiation Work Permit 6062, Revision 4, ti.a inspector noted the lack of abort criteria caused confusion among radiation protection personnel. There were additional weaknesses in the prejob briefings. The radiation protection technician
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conducting the briefing was not assertive in outlining requirements. Therefore, it was unclear that some instructions, such as the use of the personnel contamination monitor near the ccatainment building, were required to be ccmpleted, rather than simply an optional step. One worker missed part of the briefing to answer a
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telephone call Neither the worker nor radiation protection personnel attempted to ensure that all briefing information was presented and understood. It was not identified, at first, that an individual scheduled to take measurements on the fuel assembly gripper would need to wear extremity monitoring. Ultimately, a radiatiori protection supervisor intervened and provided positive guidance with respect to abort criteria, whole-body frisking requirements, and extremity dosimetry requirements.
During a second prejob briefing, the radiation protection technician relied on radiation dose information provided during a shif t turnover meeting rather than using the latest radiation survey record. The latest survey information had not been filed with the radiation work package, but a copy was available in a separate binder had the technician chosen to retrieve it. Although, in this examplo, the difference in radiation data presented by the radiation protection technician and that indicated on the latest radiation survey record was not suf ficient to constitute a problem, the practice emphasized a weakness in the licensee's process to instruct radiation workers of potential hazards.
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f Radiation protection shif t turnover meetings were conducted well, There were sufficient supplies of portable radiation protection instrumentation.
A suitable number of contract radiation protection technicians was used to supplement the licensee's staff. However, because of the outage delays, some of the supplemental radiation protection staff indicated that they did not plan on working for the licensee until the completion of the outage. Some contract radiation protection personnel planned to leave site on approxirnately November 8,1997, to enable themselves to work at another nuclear site that was scheduled to begin a refueling outage, then. Licensee representatives stated that they were attempting to find additional contract radiation protection personnel to supplement the permanent staff.
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Conclusicr s Preparation for outage activities by the radiation protection organization was satisisctory. Although radiation work permit package preparation was generally good, abort criteria were not included in all packages in which it was appropriate.
Prejob briefings needed improvement, because requirements were not clearly stated and current survey information was not always used. Shift turnover meetings were conducted well. The radiation protection staff was supplemented appropriately by contract radiation protection personnel.
R1.2 External Exoosure Controls a.
lmpection Scoce (83750)
The inspector interviewed radiation protection personnel and reviewed the following:
Job coverage
Control of high radiation areas
Radiation area posting
Access controls
Dosimetry use
Periormance improvement requests
b.
Observations and Findinas (83750)
Because of the problems with the refueling machine, there were limited opportunities for the inspector to observe radiation prctection job coverage; however, good radiation protection support was provided during the work on the re*ueling machine and during the reactor coolant system filter replacement.
On October 22,1997, a decontamination worker fell into the transfer canal as he was mopping an area inside the containment building. The individual caught himself on the edge of the walkway, but portions of his legs entered the water. Workers
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assisted the individual from the containment building and removed his anticontami_ nation clothing. First aid personnel assessed a wound on the injured-t worker's shin.- Radiation protection _ perscnnel accompanied the worker to an area to~
i perform contamination surveys and decontamination Contamination levels were below the licensee's procedural guidelines for the performance of dose calculations.
Af ter decontamination, the individual and others who came to his aid successfully
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passed through the_ personnel contaminatica monitors at the exit of the radiological-controlled area. A whole-body' count indicated no internal deposition of radioactive
. material. Bioassays for tritium were planned, as followup, Radiation protection personnel surveyed the pathway traveled by the individual and the other workers who aided the 11dividual as a precaution against the spread of radioactive
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~f contamination and hot particles.
High radiation and locked high radiation areas in the containment building were progerly posted and controlled. Radiological controlled area access controls were
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implemented ~ appropriately. Radiation workers wore dosimetry as required.
The licensee identified, in Performance Improvement Request 97-3177, an event in which an arcia with a radiation level greater than 1000 millirems per hour was not posted and controlled in accordance with regulatory requirements. On October 12, 1997, a filter cleaning debris from water in the spent fuel pool (Filter FHB11) was changed.. Radiation protection personnel provided job support. To gain _ access to the filter, a concrete shield plug had to be removed.- Wnen the filter was changed, maintenance personnel could only secure 3 of 4 bolts on the filter housing, The shield plug was not replaced in anticipation of repairs to the fourth bolt. However, during the night shif t, the system was p' aced back in service (at approximately 2:30 a.m. on October 13,1997). Radiation protection personnel were not informed l-at the time. As the filter loaded with debris, the radiation level rose. Radiation
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protection personnel were informed at approximately noon on October 13,1997, that the system was returned to service.. Radiation protection personnel performed surveys and confirmed that radiation dose rates on contact with the filter housing
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I 10 CFR 20.1003 defines a high radiation area as an area, accessible to individuals, E
in which radiat!an levels could reault in an individual receiving a dose equivalent in excess of 100 millirems in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters (1 foot) from the radiation
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- source or from any surface that radiation penetrates.' 10 CFR 20,1902(b) requires-
-the licensee to post a high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words, " Caution, high radiation area." Technical Specification 6.12 contains additio.nal requirements. Technical Specification _6.12.2 requires, in part, that areas accessible to personnel with radiation of greater than 1000 millirems. per hour shall be provided with locked doors to prevent unauthorized
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be reasonably constructed around the individual area, that individual area be barricaded. conspicuously posted, and a flashing light shall be activated as a
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warning device.
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7-The licensee acknowledged that the area was not posted as a high or locked high radiation area, and a flashing lighs was r.ot activated as a warning device. The licensoe had not finished reviewing the event and did not offer an opinion as to the soot cause of the event. Corrective actions to prevent recurence had not been finalized. The inspector identified the event as a violation of Technical Specification 6.12 and 10 CFR 20.1902(b)(482/9720-01).
Radiation protection personnel stated that no one received radiation doses exceeding the electronic, a! arming dosimeter setpoints during the night of October 12,1997, or the morning of October 13,1997. These dose setpoints were typically less than 100 millirems. The inspector observed the filter tay, architectural drawings of the aren, and radiation survey records. Based on this information and the time the violation remained undiscovered, the inspector concluded that the potential for personnel to exceed regulatory exposure limits was not substantial.
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Conclus.ikns External exposure controls were implemented properly, in most cases. Job coverage by radiation protection personnel was good. The response and followup by radiation protection personnel to an emergency situation in the radiological controlled area were excellent. A violation was identified for the failure to properly post and control a high radiation area with a dose rate greater than 1000 millirems per hour.
R1.3 Internal Exoosure Controls a.
Insnoction Scoce (E'750)
The inspector interviewed radiation protection personnel and reviewed the following:
Air sampling techniques
Respirator issue and use
Supplemental ventilation
Whole body counting
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Observations and Findinas A review of respirator issue records confirmed that individuals receiving respirators met all qualification requirements. Individuals were issued respirators matching the sizes identified during fit testing.
Radiological air sampling was properly conducted to establish airborne concentrations. Portable high efficiency, particulate air-filtered ventilation units were available and ready for use. Whole-body counts were provided when there were indications of intake of radioactive materials.
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Conclusioris
- Internal exposure controls were implemented appropriately.
' R1.4 Control of Radioactive Material and Contamination: Survevina and Monitorina a.
Insoection Scone (83750)
U The inspector interviewed radiation protection personnel and reviewed the following:
Radiation workri practices t
Personnel contamination events
Release of items from the radiological controlled area
Contaminated area posting
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Observations end Findinas Overall, radiation worker practices were satisfactory. The licensee conducted pre-outage training for radiation workers. -The training reviewed: dressing in-anticontamination clothing anrf undressing, criteria for reaching across boundaries recent events involving redworker practices, and other related topics.
The licensee was experiencing slightly more personnel contamination events than projectedi however, the inspector determined that only five of the events involved contamination levels greater than the licensee's 10,000 counts per minute threshold that required dose calculations. The inspector determined through personnel interviews that an imbalance in the fuel handling building ventilation system may have led to at least ten personnel contamination events October 8 9,1997.
Licensee representatives stated that a performance improvement request was not initiated to document the event and track corrective actions. The inspector reviewed Procedure AP 28A-OO1, " Performance improvement Request," Revision 8, and concluded that, although the initiation of a performance improvemen* 'equest in
- this case was not specifically required, the radiation protection organizawa had not been aggressive in the use of the site-wide problem identification and correction program. Licensee representatives acknowledged the inspector's comment and initiated Performance Improvement Request 97-3413.
During the review of radioactive material controls, radiation protection personnel stated that, as a practice, they released nothing from the radiological controlled area with detectable amounts of radioactive material. The inspector identified nothing during the inspection to contradict this statement; however, the inspector noted that pr.ocedural requirements were not as restrictive as the licensee's practice.
Procedure RPP O2 515, " Release of Material from the RCA," Revision 8, Section 4.5 addressed unconditional release criteria or criteria to be met prior to raleasing items
~ from the radiological controlled area. According to the procedure itenc with loose beta or gamma contamination measuring less than 1000 disintegrations per minutes.
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t or loose alpha contamination measuring less than 100 disintegrations per minute could be released imconditionally from the radiological controlled area, if the procedure was interpreted literally, and radioactive material of these quantities was relesed, ths release would constitute a violation of 10 CFR 20.2001, " General Requirements for Waste Disposal." There has been no level established that is below regulatory concern. Radiation survey requirements were discussed in Health Physics Positions 072 and 073 in NUREG/CR 5569, Revision 1, and NRC Information Notice 85 92.
Procedure RPP 02-515 also prav,ded guidance for conditionally releasing contaminated items from the radiological controlled area. Section 9.4.1 of the procedure requires, in part, that Form RPF 02 515 02 be completed to document the release and that the items be labeled. According to the Health Physics Shift Log Book, Snubbers 17994 and 20231 were released from the radiological controlled area on October 12,1997. However, the inspector determined that Form RPF 02-515-02 was not completed, and the snubbers were not labeled to identify the presence of radioactive contamination. The inspector identified the f ailure to follow procedural guidance as a violation of Technical Specification 6.8 which requires the licensee to implement procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 (482/9720 02).
Licensee representatives stated that they would review the guidance provided by
- this procedure to determine the best means of revising it to reflect their actual practice for maintaining contro! of radioactive material.
The inspector reviewed contaminated area postings and confirmed that postings met procedural requirements. However, the senior resident inspector discussed an
observation made on or about August 7,1997. The senior resident inspector noted an area in the fuel handling building in which the area posting around the spent fuel pool was not visible. The area was within a notched area in the fence around the spent fuel poolin front of the entrance to the fuel handling building.
Procedure RPP 02 215, "Postirig of Radiological Controlled Areas," Revision 11, Section 9.1.2, requires that posted areas be clearly and conspicuously marked at all accessible sides and entrances. The inspector identified this failure to rollow procedural guidance as a second example of a violation of Technical
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Specification 6.8, which requires the licensee to implement procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 (482/9720-03). The inspector noted the licensee had addressed this issue and placed additional posting around the spent fuel pool so that posting during the inspection was correct.
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l Radiological worker practices were satisf actory. Better procedural guidance was I
needed with respect to the control and release of radioactive materials. A violation
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l was identified, because accountability was not properly maintained when radioactive material was conditionally released from the radiological controlled area. A violation i
was identified, because posting in a contaminated area around the spent fuel pool
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was not conspicuous.
R5 Staff Tra;ning and Qualification The inspector reviewed the qualifications ')f the new radiation protection manager er.d selected examples of contractor radiation protection technicians resumes. The radiation p'otection manager met the guidelines of Regulatory Guide 1.8, and the contract radiation protection technicians met the guidelineo of ANSI /ANS 3.11978.
X1 Exit Meet'ng Sur.imary The inspector presented the inspection results to members of licensee management at an exit meeting on October 24,1997. The licensee acknowledged the findings presented. No prop ;etary information was identified.
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s AITACHMENT P.ARIIALLIST OF. PERSQRCONIAQlED Licmane
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M. Blow, Manager Chemistry / Radiation Protection T. Damashek, Licensing Supervisor R. Hammond, Health Physics Operations Supervisor O. Maynatd, President / Chief Executive Officer
= B. McKinney, Plant Manager
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D. Moore, Maintenance Manager L. Nilges, ALARA Supervisor
_ C. Reekie, Licensing R. Stumbaugh, Operations estructor C. Swartzendruber, Principal Engineer C. Warren, Vice President of Operations / Chief Operating Officer NRC F. Ringwald,- Senior Resident inspector B. Smalldridge, Resident inspector.
INSPECTION PROCEDURES USED R3750 Occupational Radiation Exposure LIEMS_DfENED, CLOSEDJDEISCUSSED
. Onened 482/9720 01 VIO Fallare to post and control a high radiation area 487/9720 02 VIO.
Failure to follow procedural requirements with regard to th e conditional release of radioactive material-482/9720 03
, VIO Failure to follow procedural requirements with regard to posting a contaminated area
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Closed None
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LIST _OEDOCUMENTS REVjLWED
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' AP 25B 100 Radiation Worker Guldelines, Revision AP 258 300 RWP Program, Revision 6 AP 28A-001 Performancklmprovement Request, Revision 8 -
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RPP 02 215 _ Posting of Hadiological Controlled Areas, Revision 11
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RPP 02 305 Personnel Contamination Surveys, Revision 9
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RPP 02 310 Personnel Decontamination, Revision 3 l
RPP 02 510 Hot Particle Contamination Control, Revision 4 j
RPP 02 515 Release of Material from the RCA, Revision 8 l
RPP 02 605 Control and inventory of Radioactive Sources. Revision 7
RPP 04110 ALARA Reviews, Revision 3
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