IR 05000482/1999012

Insp Rept 50-482/99-12 on 990816-20.No Violations Noted. Major Areas Inspected:Solid Radioactive Waste Mgt Program, Radioactive Matls Transportation Program,Facilities & Equipment,Staff Kowledge & Performance & Staff Training

ML20216F171
Person / Time
Site:	Wolf Creek
Issue date:	09/14/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216F168	List: IR 05000482/1999012 ML20216F164
References
50-482-99-12, NUDOCS 9909210179
Download: ML20216F171 (10)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-482 License No.: NPF-42 Report No.: 50-482/99-12 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane, NE Burlington, Kansas Dates: August 16 20,1999 Inspector (s): James S. Dodson, Radiation Specialist Plant Support Branch Approved By: Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information l

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! -2-EXECUTIVE SUMMARY Wolf Creek Generating Station NRC inspection Report No. 50-482/99-12 The NRC conducted an inspection of the so!id radioactive waste management and radioactive material transportation programs. Areas reviewed included: the solid radioactive waste management program, radioactive material transportation program, facilities and equipment, staff knowledge and performance, staff training and qualifications, and quality assurance activitie Plant Support

• The licensee met regulatory requirements associated with the solid radioactive waste management program. Radioactive material was correctly stored and controlle Radioactive waste was correctly classified and stabilized for burial. Waste manifests were prepared in accordance with regulatory requirements (Section R1.1).

• The licensee met regulatory requirements for the packaging and shipping of radioactise materials and radioactive waste. Packages were properly marked and labeled, and radioactive material transport vehicles were properly placarded. Shipping documentation contained the required information (Section R1.2).

• Some problems were observed with the material condition of the licensee's radwaste j facilities; one pipe tee and one valve showed significant surface rust (Section R2). I

• The individuals responsible for training, routine oversight, transfer, packaging, and transport of radioactive material were knowledgeable of training and retraining requirements. Additionally, these individuals were knowledgeable of waste classification, packaging, marking, labeling, storage, documentation, vendor supplied computer software operation, and radioactive material transportation regulations (Section R4).

• The licensee provided solid radwaste and transportation personnel with the appropriate initial training and retraining (Section RS).

• The biennial quality assurance audit of the Process Control Program was not comprehensive. The audit only addressed observation of a radwaste shipment, reviews of task observations, a summary of Performance improvement Requests, and regulatory commitments. The Process Control Program contained approximately 13 areas and implementing procedures for processing, packaging, and transportation of radioactive wastes. As a result, this narrowly focused audit provided management with limited information needed to assess the program's performance (Section R7).

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Report Details

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! IV. Plant Support i R1 Radiological Protection and Chemistry Controls l

R Solid Radioactive Waste Manaaement Proaram Inspection Scope (86750)

The inspector interviewed licensee personnel and reviewed the following program areas:

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- Waste storage and container accountability

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. Waste stream sampling results

. Waste classification

- Waste characteristics

. Waste shipment manifests Observations and Findinas Waste Storaae and Container Accountability During tours of the radiological controlled areas, the inspector confirmed that radioactive l

waste was stored in accordance with commitments in the Updated Final Safety Analysis l Report, Chapter 11.4. The inspector verified that randomly selected radioactive material containers were properly labeled and confirmed that the licensee's tracking system listed the correct location and status of the container Waste Stream Samolina The inspector reviewed the analysis results and the associated evaluations for the eight identified waste streams. The inspector determined that sampling and analyses were completed at the required intervals. The scaling factors used in the vendor supplied computer code were verified with current analysis results as required by procedur .. Analyses were performed by a vendor laboratory and the licensee as required by procedure. During the review of selected waste stream analysis packages, the inspector noted that waste stream analysis package No. 9 was missing the Independent Laboratory Data Checklist in accordance with management expectations. The licensee entered the item in the corrective action program.

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! Waste Classification i

I The licensee used a vendor supplied computer scftware code to perform the calculations necessary to classify radioactive waste. The inspector reviewed sample results from selected radioactive waste shipments and confirmed that the waste shipments were properly classified in accordance with 10 CFR 61.5 V,

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-4 Waste Characteristics ,

Through record review and observations, the inspector confirmed that the licensee met the structural integrity requirements of 10 CFR 61.56 (b)(1) by using high integrity containers. No adverse findings relating to the licensee's radioactive waste characteristics had been identified by burial site representative Manifests The inspector reviewed random shipping documentation and confirmed that the licensee accurately prepared manifests and included the information required by 10 CFR Part 20, Appendix G. The shipment manifests included a certification that the transported material was properly classified, described, packaged, marked, labeled, and in proper ;

condition for transport. The certification was signed and dated by an authorized l licensee representativ l

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l Conclusions The licensee met regulatory requirements associated with the solid radioactive waste management program. Radioactive material was correctly stored and controlle Radioactive waste was correctly classified and stabilized for burial. Waste manifests were prepared in accordance with regulatory requirement R1.2 Radioactive Material Transportation Proaram Inspection Scoce (86750)

The inspector interviewed licensee personnel and reviewed selected examples of the following materials: l

. Packaging

. Radiation surveys ,

. Shipping paper documentation l

= Package marking and labeling

. Loading and storage, blocking and bracing

. Vehicle placarding i

. Driver instructions

. Emergency response information  ; Observations and Findinas Packaaina The inspector reviewed A, values for selected radionuclides in the licensee's waste classification computer data base and confirmed that they matched the values in 49 CFR 173.435. The licensee maintained records that documented Type B packages used by the licensee were designed to meet the applicable requirements specified in 10 CFR 71.1 ,

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5-Radiation Surveys Radiation surveys were conducted by the inspector during tours of the radioactive waste l

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processing and storage facilities to ensure that external radiation levels were within the allowable limits of 49 CFR 173.441. The inspector verified that radioactive waste package external radiation levels were within allowable limits for randomly selected package Packaae Markina. Labelino. and Loadina and Vehicle Placardina The inspector reviewed shipping documentation packages and determined that packages were properly marked and labeled and that radioactive material transport vehicles were properly placarded in accordance with 49 CFR 172.504 and 172.50 Shiocina Pacers and Documentation The inspector reviewed selected examples of shipping documentation and confirmed that the licensee provided the shipping papers and information required by 49 CFR Part 172, Subpart C, and the emergency response information required by 49 CFR Part 172, Subpart G. Additionally, the inspector verified that shipping permits, licenses, certificates of compliance, user lists, and shipping regulations were curren c. Conclusions l The licensee met regulatory requirements for the packaging and shipping of radioactive materials and radioactive waste. Packages were properly maued and labeled, and radioactive material transport vehicles were properly placarded. Shipping documentation contained the required informatio R2 Status of Radiological Protection and Chemistry Facilities and Equipment a. Insoection Scoce (86750)

The inspector reviewed associated documentation and toured the radwaste building and interim onsite storage facility. The inspector also viewed radwaste storage tanks, pumps, valves, and associated pipin b. Observations and Findinos The licensee made no significant changes to solid radwaste f acilities since the last inspection in this area. Changes in equipment were reflected in the current versions of the Process Control Program and implementing procedures. The inspector noted no deviations from commitments in the Updated Final Safety Analysis Report, Chapter i 11.4, due to the revision which was in process to correct both fidelity and terminology

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issues identified by the license During the tours of the radwaste building and interim onsite storage facility, the inspector noted that the housekeeping was acceptable.

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6-To selectively review the material conditions in the licensee's radwaste facility, the inspector asked to see radwaste storage tanks, pumps, valves and associated pipin The inspector noted that there were problems with the material condition of a reducer pipe tee and Valve HBV-422 in floor drain tank room No. A. Specifically, there were signs of significant sudace rust on the pipe tee and in some areas on the valve. The licensee initiated Work Request WR#99-016899 to address this issu c. Conclusions Housekeeping in the solid radwaste facilities was acceptable. Some problems were observed with the material condition of the licensee's radwaste facilities; one pipe tee and one valve showed significant surface rus R4 Staff Knowledge and Performance a. Insoection Scope (86750)

The inspector interviewed a quality assurance specialist, health physics supervisor radwaste, and the training instructor involved in the radioactive material transportation program, b. Observations and Findinas The quality assurance specialist who conducted quality assurance observations and surveillances was knowledgeable of regulatory and procedural requirements for solid radioactive waste management and transportation. The training instructor responsible for radwaste personnel training was knowledgeable of the regulatory training and retraining requirements. The health physics supervisor radwaste was knowledgeable of radioactive waste classification, packaging, marking, labeling, storage, documentation, vendor supplied computer software operation, and radioactive material transportation regulation c. Conclusions The individuals responsible for training, routine oversight, transfer, packaging, and transport of radioactive material were knowledgeable of training and retraining requirements. Additionally, these individuals were knowledgeable of waste classification, packaging, marking, labeling, storage, documentation, vendor supplied computer software operation, and radioactive material transportation regulation R5 Staff Training and Qualification a. Inspection Scope (86750)

The inspector reviewed initial training lesson plans, retraining lesson plans, and training records for the health physics supervisor radwaste, and two radwaste technician .

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-7- Observations and Findinas Training lesson plans and records confirmed that the licensee provided the appropriate initial training and periodic retraining in Department of Transportation and NRC regulatory requirements. Additionally, the training and retraining programs included instructions and a review of operating procedures for personnelinvolved in the transfer, packaging, and trarssport of radioactive materia Conclusions The licensee provided solid radwaste and transportation personnel with the appropriate initial training and retrainin R7 Quality Assurance in Radiological Protection and Chemistry Activities Inspection Scope (86750)

The inspector interviewed licensee personnel and reviewed the following items:

. Quality assurance audit

. Quality assurance surveillances

. Vendor audits

. Self-assessments

. Performance improvement Requests Observations and Findinas The licensee conducted one audit, WCNOC OA Audit K-508, since the previous NRC inspection of solid radioactive waste management and transportation activitie Procedure AP 20A-003, Revision 3, " Audit / Surveillance Scheduling," identified the 24-month audit elements as the Process Control Program, implementing procedures for processing, packaging, and transportation of radioactive wastes including Type B and fissile quantities of radioactive materials and low-level radioactive waste. The elements of the Process Control Program, as delineated in Procedure AP 31 A-100, Revision 2,

" Solid Radwaste Process Control Program," were: waste stream identification, solidification / encapsulation methods, operation and maintenance of dewatering equipment, high integrity container usage, waste characterization, waste classification, waste packaging, regulatory requirements, quality control, certifications, waste management facility requi ements, administrative controls, and surveillance requirement The scope of the program audit included observation of a radwaste shipment, a review of task observations, a summary of Performance improvement Requests, and regulatory commitments. Due to the narrow scope of the audit, the inspector determined that the audit was not comprehensiv _

Since the previous inspection, quality assurance personnel conducted four observation . These observations were general and addressed segments of activities and practice I l

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-8-The observations provided minimal oversight of radwaste management and transportation activitie Three vendor audits were conducted for radwaste management related support functions. The vendor services were for the waste stream analysis laboratory and radwaste processing. The results of the vendor audits were satisfactor One self-assessment audit was conducted by quality assurance during this inspection period. Deficiencies identified by the evaluators were properly placed in the corrective action program. The inspector noted no problems with the assessmen The inspector reviewed a summary of performance improvement requests and selected performance improvement requests relating to transportation and radioactive waste management activities. Selected corrective actions and closure documentation were reviewed and determined to be adequate. The inspector noted that corrective actions were completed in a timely manne c. Conclusions The biennial quality assurance audit of the Process Control Program was not comprehensive. The audit only addressed observation of a radwaste shipment, reviews of task observations, a summary of Performance Improvement Roquests, and regulatory commitments. The Process Control Program contained approximately 13 areas and implementing procedures for processing, packaging, and transportation of radioactive wastes. As a result, this narrowly focused audit provided management with limited information needed to assess the program's performanc V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting on August 20,1999. The licensee acknowledged the findings presente No proprietary information was identifie l I

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ATTACHMENT l SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee B. McKinney, Plant Manager S. Koenig, Manager, Performance Improvement and Assessment M. Blow, Manager, Chemistry and Radiation Protection K. Hall, Supervisor, Corrective Actions V. Cannales, Supervisor, Quality Evaluations S. Burkdoll, Supervisor, Health Physics and Chemistry Training ,

C. Medenciy, Supervisor, Health Physics Radwaste C. Stone, Quality Assurance R. Skiles, Health Physics Radwaste Instructor C. Reekie, Engineering Specialist, Licensing l

NRC )

R. Kopriva, Senior Project Engineer INSPECTION PROCEDURES USED 86750 Solid Radioactive Waste Management and Transportation of Radioactive Material

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PARTIAL LIST OF DOCUMENTS REVIEWED Lists of Performance improvement Requests relating to the inspection areas (3/1/98 to 8/15/99)

Performance Imorovement Reauests j l

PIR-97-0737 PIR-98-0011 l PIR-98-0624 l PIR-98-0759 PIR-98-0765 PIR-98-0791 PIR-98-0939 PIR-98-1286 PIR 98-2090 PIR-98 2811 PIR 98-3327 PIR-98-3607 PIR-99-0801 '

PIR-99-0948 PIR-99-2150 PIR-99-2316

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O t-2-WCNOC OA Audit K-508, February 18 to March 19,1999 Self Assessment Report K-473 dated April 10,1997 Sucolier Evaluation Reoorts T105 dated September 4,1998 TB66 dated March 11,1998 SC75 dated September 3,1908 Quality Assurance Observations (Plant Evaluation Checklist) OB 98-0138, OB 98-0352, l OB 98-0445, and OB 99-0005 j l

Procedures  !

AP 17C-017 " Manager Chemistry / Radiation Protection Duties and Responsibilities," i Revision 2  !

AP 20A-002 " Audit System," Revision 4 AP 20A-003 " Audit / Surveillance Scheduling," Revision 3 AP 20A-004 " Audit Procedure," Revision 4 ,

AP 20A-005 " Surveillance Procedure," Revision 3 AP 25-001 " Radiation Protection Quality Program Requirements," Revision 1 AP 28D-001 "Self 4 ssessment Process," Revision 4 AP 30D-010 " Contractor Training and Qualification," Revision 1  ;

AP 30D-100 " Health Physics Training Program," Revision 1 AP 30G-001 " Training, Qualification, and Certification of Audit Personnel," Revision 2 AP 31-001 " Packaging for Transporting Type B and Fissile Quantities of Radioactive Materials Quality Program Reouirements," Revision 1

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AP 31 A-001 " Low Level Radioactive Waste Quality Program Requirements,"

Revision 1 AP 31 A-100 " Solid Radwaste Process Control Program," Revision 2 AP 31B-001 " Hazardous Waste Management," Revision 2 RPP 07-101 " Control of Radioactive Material Management Software and Data Bases,"

Revision 5 RPP 07-110 " Solid Radwaste Packaging," Revision 5 RPP 07-111 " Handling Cartridge Filters," Revision 7 RPP 07-120 " Preparation and Shipment of Radioactive Waste," Revision 11 RPP 07-121 " Preparation and Shipment of Radioactive Material," Revision 11 RPP 07-130 " Verification of Free Standing Water in High Integrity Containers,"

Revision 2 RPP 07-131 " Bead Resin / Activated Carbon Dewatering Procedure for CNSI 14-215 or Smaller Liners," Revision 3 RPP 07-140 " Mixed Waste Handling, inspection and Storage," Revision 4 At 02B-001 " Resin Monitoring Guidelines," Revision 1 Al 21-002 " Standards for Completion of Fundamentals Qualification Special Qualification Card," Revision 0 Al 25A-002 " Radiation Protection Interdepartmental Proi n Review," Revision 0

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Al 28D-001 " Wolf Creek Performance Observation Prograin, Revision 3 Al 30E-005 " Instructor Training, Qualification, Certification, and Continuing Training,"

Revision 5