IR 05000482/1998006

Insp Rept 50-482/98-06 on 980202-06.No Violations Noted. Major Areas Inspected:Review of Radiation Protection Program Activities

ML20203L597
Person / Time
Site:	Wolf Creek
Issue date:	02/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203L594	List: IR 05000482/1998006 ML20203L590
References
50-482-98-06, 50-482-98-6, NUDOCS 9803060133
Download: ML20203L597 (13)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

Docket No.: 50482 License No.: NPF42 i Report No.: 504 82/98-06 Licensee: Wolf Creek Nuclear Operating Corporation Facility; Wolf Creek Generating Station Location: 1550 Oxen Lane, NE Burlington, Kansas Dates: February 2 to 6,1998 Inspecto!: Gilbert L. Guerra, Jr., Radiation Specialist Approved By: Blaine Murray, Chief

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Plant Support Branch Division of Reactor Safety Attachment : SupplementalInformation

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P 9803060133 990227 PDR ADOCK 05000482 O PDR e v-e w m-aw e- - ry w.r- r- v +-W -- M--"

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EXECUTIVE SUMMARY-Wolf Creek Generating Station NRC Inspection Report 50-482/98-06

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The announced, routhe inspection reviewed radiation protection program activities. Areas

' reviewed included; external and internal exposure control programs and control of radioactive

> material and contaminatio Plant Supoort

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An effective radiation protection program was maintained including: radiological controls and postingo, extemal dosimetry, and extemal exposure controls (Section R1.1).

A noncited violation was identified for failure to follow radiological controlled area egress

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Proper total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA)

evaluations for respirator use were performed. Whole-body counting and intemal dosimetry programs were effectively implemented (Section R1.2).

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Proper radiation surveys were performed and documented. The portable radiation protection instrumentation program was properly maintained (Section R1.3).'

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Radiation protection procedures contained appropriate detail (Section R3.1).

' An appropriately staffed radiation protection organization was maintained (Section R6).-

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Corrective actions were implemented in a timely manner (Section R7.1).

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Report Details Summarv of Plant Status The Wolf Creek Generating Station was at power operations during this inspection No events occurred during this inspection that adversely affected the inspectio IV. Plant Suonort R1 Radiological Protection and Chemistry Controls R Extemal Exoosure Controls a, Ipsoection Scooe (83750)

The inspector conducted several tours of the radiological controlled area. Discussions were held with radiation protection personnel. The following items were reviewed:

a Radiological controlled area access / egress controls

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Control of high radiation areas

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Issuance and control of locked high radiation area keys

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Job coverage by radiation protection personnel

- Dosimetry use

.- Containment entries and neutron monitoring

. Dose consequences due to core axial offt t b. Observations and Findinos The inspector observed personnel process in and out of the access / egress area of the radiological controlled area. The inspector noted that personnel wore their thermoluminescent and electronic dosimetry properle Appropriate access controls were used, and radiation work permits were written containing appropriate safety informatio Radiation protection personnel at the access control desk were available to assist personnel processing in and out of the radiological controlled area. A recently installed entry tumstile to prevent personnel from entering the radiological controlled area without required electronic dosimeters was an improvement. The inspector noted that the licensee planned to enhance this system by providing an electronic interlock for thermoluminescent dosimeters also.

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Tours of the radiological controlled area revealed that radiation, contamination, and high radiation areas were properly controlled and posted. All Technical Specification required

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locked high radiation area doors were locked and properly poste The inspector reviewed locked high radiation area key controi and found that alllocked high radiation area keys were properly controlled. A list of authorized personnel was maintained by security. Only personnel on the iist were issued locked high radiation area

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-4-keys. The security access / egress :ystem did not allow personnel to exit the protected area without retuming the key. Keys for locked high radiation areas were appropriately issued and controlle On October 8,1997, the licensee identified that a security watch person exited the l

radiological controlled area by passing under the radiological controlled area rope-barrier near the hot machine shop, a route other than through the access control point without obtaining direction from health physics personnel. Technical Specification 6.8.1.a

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requires, in part, that written procedures be established, implemented, and maintained covering the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1) lists radiation protection procedures for access control to radiation areas. Procedure AP 25A-001, " Radiation Protection Manual," Revision 2, Section 6.7.4.1, states, " Access to the radiological controlled area shall normally be through Access Control. Entrance to or exit from the radiological controlled area by any other route shall not be permitted except under the direc+icq of health physics personnel." Section 6.7.4.1.1 states, "No entrance or exit may be made by any route other than through such designated points, when applicable." The inspector reviewed the licensee's corrective actions which included (1) surveying the affected area for radioactive contamination, (2) having the individual exit through access control, (3) notifying the superintendent security, and (4) restricting the individual from the radiological controlled area. Although this violation is willful, it was brought to the NRC's attention by the licensee, it involved isolated actc of a low-level individual, and it was addressed by appropriate remecital action. Therefore, this nonrepetitive, licensee-identified, and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-482/9806-01).

The inspector observed radiation protection technicians perform job coverr,ge dutie Activities observed included locked high radiation area security verification, radiation and contamination surveys in support of lighting replacement for burned out lights, and seal water filter change out. The inspector noted that radiation protection technicians were diligent in performing their duties. The prejob brief for the seal water filter change out was properly conducted and presented proper information with regard to safety, radiological controls, and personnel dutie The licensee used a vendor to process their thermoluminescent dosimeters. The vendor processing program was National Voluntary Laboratory Accreditation Program accredited in nine categories. Electronic dosimeter dose results used for accounting daily dose estimates were conservative with regard to thermoluminescent dosimeter dose _. ._

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-5-The inspector gathered data on containment entries, neutron dose rates, and personnel l exposures. The following table presents the date obtaine Number of containment 46 36 45 entries Total number of individuals 327 404 496 involved in all entries Review of the data revealed that there w:;s not an increase in the number of containment entries made in the last 3 years. A slight increase was noted in the total number of individuals involved in all entries per year. The total number of individual entries identified in the table represents individuals who may have entered and exited more than once during any one containment entr A review of neutron survey data from 1994 to the present did not show an increase of neutron dose rates in the containment building. Surveys of neutron dose rates were conducted by the licensee in the reactor containment building at 100 percent reactor power. Neutron dose rates in the containment building ranged from 2 - 60 mrem per hour. A review of the licensee's spectral analysis of the containment building showed that the average neutron energy spectra in the reactor containment building at power was 20-25 kilo-electron volts (kev).

The licensee utilized a four-chip therrnoluminescent dosimeter consisting of two lithium borate chips and two calcium sulfate chipc. Specific dosimeters for neutron exposure were not issued during containment entries. However, the licensee could calculate the neutron exposures for workers using neutron dose rate survey information and stay time data. Neutron doses are part of the deep dose equivalent that is reported when thermoluminescent dosimeters are processed. Personnel exposures due to neutron radiation for 1996 were as follows: 36 mrem for the maximum exposed individual and a collective dose of 756 mre Starting in 1990, the licensee changd neutron survey instrument calibration vendors that resulted in a change in the use of calibration sources. The average neutron energy for a californium-252 source is 2.35 Mev and for a plutonium-beryllium source is 4.5 Mev a difference of about a factor of 2. Because neutron doses were calculated using neutron survey information and stay time data, the inspector inquired about the neutron dose calculation, to determine if the calculation took into account the differerice in instrument readings due to the factor of 2 change in average neutron energy for the instrument calibration sources. The licensee stated that the neutron dose calculation was not changed due to the change in survey instrument calibration sources. This made the neutron dose calculation more conservative since the survey instrument over-response to neutron dose rates in containment was greater for plutonium-beryllium than for californium 252. For reporting purposes the neutron dose is a component in the deep dose equivalen ~ a

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6-L The core axial offset conditions resulted in general plant dose rates increasing by about

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50 percent. This caused the licensee to exceed their outage goal of 140 person-rom.

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- This goal was revised to 220 person-rem during Refuel Outage IX; however, the final outage exposure result was 248 person-rem.

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Management support for ine ALARA program was evident in the implementation of longer reactor coolant cleanup times. The reactor core was redesigned during Refuel i- . Outage IX, and the licensee does not expect core axial offset conditions to be a >

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- significant exposure concem in the future.-. However, the licensee was keeping current of

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industry developments regarding this issue. The observed dose rates have trended

' ~down since the outage, and the licensee's operating goal for 1998 (nonoutage year) is 14 person-rem.

j Overall, housekeeping within the radiological controlled area was good.

Conclusions  ;

. Appropriate radiological controlled area access controla were maintained. Radiation,

! contamination, and high radiation areas were properly controlled and posted. A good F external dosimetry program was maintained. Overall, a good extemal exposure control

program was implemented. A noncited _ violation was identified for failure to follow radiological controlled area egress procedures.

R1.2 Intemal Exposure Controls 4 Inspection Scope (83750)

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Selected radiation protection personnel involved with the intemal exposure con. ci i program were interviewed. The following items were reviewed

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. Respiratory protection program

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- : Personnel contamination events

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' Internal dose assessment program

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t bc . Observations and Findinas

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A good respirator maintenance program was implemented. Proper storage of respirators was observed.' Full-face respirators ready for use were inspected monthly.- No problems were identified with the respiratory protection maintenance program.

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- The licensee appropriately performed the required reviews for the use of resp lratory protection equipment to minimize the TEDE. ALARA reviews were properly performed to

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determine whether respiratory protection equipment would be effective in minimizing the total dose received. The inspector found the licensee's TEDE/ALARA review procedure to be appropriat a

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7-A good whole-body counting program was maintained. The inspector noted that the licensee utilized a sodium iodide " chair" type whole-body counting system. A proper calibration and quality control program was maintained for the whole-body counte Six-month calibrations were performed, and quality control checks including energy calibrations were performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Calibration and quality control checks of the whole body counter systems were conducted as required using National Institute of Standards and Technology (NIST) traceable source The inspector noted that appropriate evaluations of airbome radioactive materialintakes were performed. The evaluations were based on whole-body count results, and dose results were calculated using appropriate method &. The inspector reviewed internal dose assessments performed by the licensee and determined that the dose assessments were poperly evaluated, Conclusions A good respirator maintenance program was implemented, Proper TEDE/ALARA evaluations for respirator use were performed. Whole-body counting and internal dosimetry programs were effectively implemented. Appropriate evaluations of intemal intakes were performe R1.3 Control of Radioactive Materials and Contamination. Survevs. and Monitorina Insoection Scooe (83750)

The inspector interviewed radiation protecuon personnel and reviewed the following:

Personnel contamination monitor use

Control of radioactive material

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Portable instrumentation calibration and performance checking programs

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Release of items from the radiological controlled area

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Sealed radioactive source accountability

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Sealed radioactive source leak testing Observations and Findinas Personnel contamination monitors were appropriately used and maintained. Personnel observed by the inspector used the personnel contamination monitors properly, Radiation protection technicians stationed at the radiologically controlled egress area provided proper direction and assistance to station workers exiting the radiological controlled are All radioactive material observed was property labeled and posted. Containers of radioactive materials were properly labeled and controlled. Control of radioactive material was goo ______.___a

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I-8-The inspector noted that several performance improvement requests (PIR) were initiated because of items (tools, hoses) found or used from the hot tool room that were '

contaminated. Specifically, PIRs 96-3062,97-0344, and 97-0641 documented these events. Corrective actions for all these PIRs were developed under PIR 96-3062, which included increasing personnel awareness and including discussions on this issue in training classes. PIR 96-3062 was closed on August 29,1997; however, on November 6,1997, an individual was contaminated; potentially by a flashlight issued from the hot tool room. The inspector reviewed Procedure AP 25B-100, ' Radiation Worker Guidelines," Revision 5, which states that tools and equipment that are stored in a hot tool crib or gang box and are ready for issue should meet the following criteria:

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<1000 dpm Beta-Gamma per 100 cm squared or object

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<20 dpm Alpha per 100 cm squared or object

. <3000 cpm at contact (fixed).

The contaminated items documented in the condition reports exceeded the above criteria. The inspector noted that the hot tool room was surveyed by radiation protection personnel once every 2 weeks including a random survey of items in the hot tool roo The inspector commented that radiological controls for the hot tool room have not been effective. Radiation protection management acknowledged the inspector's comment and stated that a review of the appropriateness of the controls implemented for the hot tool room would be conducte A good portable radiation protection instrumentation program was maintained. An adequate supply of portable instrumentation was observed. Allinstrumentation in use was appropriately source checked daily. A program to investigate the use of portable instrumentation when the instrument failed the source check was in place.

l Neutron survey meter instrumentation was reviewed for proper calibration and energy response testing. Neutron survey instrumentation calibrations were performed by a

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vendor. A review of calibration certification documents noted that the neutron survey meters were calibrated using a PuBe (plutonium-beryllium) source that was NIST traceable. These meters were calibrated to exposure rates ranging from 2 mrem per hour through 200 mrem per hour. The inspec'or noted from review of containment surveys at 100 percent power that neutron dose rates were between 2 and 60 mrem per hour. The inspector determined that the licensee obtained proper calibrations for the neutron survey instrumentatio The inspector reviewed a number of radiation surveys and determined that the surveys were documented in a clear and consistent manner. Radiation surveys posted at entrances to rooms appropriately reflected the radiological conditions in the room Inventories of radioactive sources were reviewed. The inspector noted that inventories and leak tests of sealed radioactive sources were perfomied every 6 months as require . _ _ _ _ _ _ _ _ .

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. Conclus10D1 Station workers used the personnel contamination monitors properly. Proper radiation surveys were performed and documented in a clear and consistent manner and were posted at entrances to rooms within the radiologically controlled area. The portable radiation protection instrumentation program was properly maintaine R3 Radiologicel Protection and Chemistry Procedures and Documentation R Radiation Protection Procedures insoection Scooe (83750)

- The inspector reviewed selected radiation protection procedures, Observation and Findinas A list of radiation protection procedures reviewed for information pertaining to this inspection can be found in the attachment to this report. Good procedures were maintained that provided appropriate detail to the radiation protection staf Conclusions l

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Radiation protection procedures were appropriat R6 Radiological Protection and Chemistry Organization and Administration I Insoection Scooe The inspector reviewed the radiation protection organizatio Observations and Findinas The inspector noted that the radiation protection and the chemistry organizations were combined under one manager. The organization was appropriately staffed to carry out its duties. The licensee has submitted an amendment for changes to be made in organization titles, specifically, the change of the superintendent health physics 'd superintendent chemistry to the manager chemistry / health physic Conclusions The radiation protection organization was appropriately staffe l l

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R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Audits j Insoection Scoos (83750)

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The inspector reviewed audits, self-assessments, and evaluations for information and performance improvement requests to determine the licensee's ability to identify, resolve, and prevent problems in radiological control, Observations and Findinos One audit and two self-assessmeiits were performed that provided radiation protection management with good insight into the performance of the radiation protection progra Several evaluations were performed by the licensee that provided good observations of radiological work activitie The inspector noted that the licensee's identification threshold for generating performance improvements requests was proper and that the licensee was effective in evaluating the conditions and taking proper timely corrective action. No negative trends were identified by the inspector during this review, Conclusions The licensee effectively implemented corrective actions in a timely manner, R8 Miscellaneous Radiological Protection and Chemistry issues (Closed) Violation 50-482/9720-01: Failure to cost and control a high radiation area The inspector verified that the corrective actions described in the licensee's response letter, dated December 12,1997, were implemented. No additional problems were identified dealing specifically with the control of high radiation area .2 (Closed)- Violation 50-482/9720-02: Failure to follow orocedural recuirements with regard to the conditional release of radioactive material The inspector verified that the corrective actions described in the licensee's response letter, dated December 12,1997, and NRC letter dated January 14,1998, were implemented. No additional problems were identified dealing specifically with the conditional release of radioactive materia ,

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-11-V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on February 6,1998. The licensee acknowledged the findings presented. No proprietary information was identifed.

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee

- M. Angus, Manager, Licensing and Corrective Action M. Blow, Superintendent Chernistry/ Radiation Protection T. Damashek, Supervisor, Licensing R. Hammond, Health Physics Supervisor, Projects J. Harris, Health Physics Supervisor, Support B. McKinney, Plant Manager C. Reekie, Licensing -

J. Schepers, Health Physics Supervisor, Operation R. Stumbaugh, Health Physics Supervisor, ALARA/Decon C. Warren, Vice President, Operations i

NBC D. Graves, Senior Project Engineer T. McKemon, Operations Examine B. Nicholas, Senior Radiation Specialist J. Pellet, Chief, Operations Branch J. Ringwald, Senior Resident inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEMS OPENED. CLOSED. AND DISCUSSED Ooene_d 9806-01' NCV Radiological controlled area barrier violation Closed 9720-01 VIOL Failure to post and control a high radiation area 9720-02 VIOL . Failure to follow procedural requirements with regard to the conditional release of radioactive material 9806-01 NCV Radiological controlled area barrier violation Discussed None

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-2 LIST OF DOCUMENTS REVIEWED Procedures -

AP 258-100 Radiation Worker Guidelines, Revision 5 RPP 01-405 HP instrument Program, Revision 9 RPP 02105 RWP, Revision 10 RPP 02 205 Radiological Survey Frequency Requirements, Revision 7 RPP 02 210 Radiation Survey Methods, Revision 13 RPP 02-215 Posting of Radiological Controlled Areas, Revision 11 RPP 02-515 Release of Material From the RCA, Revision 9 RPP 02-605 Control and Inventory of Radioactive Sources, Revision 8 RPP 03-305 issuance of Respiratory Protective Equipment, Revision 11 RPP 05-606 Respirator Fit Testing with the TSI Portacount, Revision 5 RPP 05 705 ND Whole Body Counter Operation, Revision 7 RPP 05-710 WBC-8000 Nuclear Data People Mover System Operation, Revision 10 RPP 06-705 ND Whole-Body Counter Calibration, Revision 2 RPP 06-710 WBC-8000 Nuclear Data People Mover System Calibration, Revision 4 Audilli SEL 97-002 Health Physics Organization 3/7/97 SEL 97-054 issue of TLDs 12/19/97 K-476 Radiation Protection 7/30/97 Q1titi Refuel IX Health Physics Outage Report Performance improvement Request - 97-3630, 96-3062, 97-0344, 97-0641