IR 05000482/2004008

IR 05000482-04-008; Wolf Creek Generating Station; Radioactive Material Control Program

ML042730221
Person / Time
Site:	Wolf Creek
Issue date:	09/29/2004
From:	Shannon M Division of Reactor Safety IV
To:	Muench R Wolf Creek
References
IR-04-008
Download: ML042730221 (17)

Text

ber 29, 2004

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2004008

Dear Mr. Muench:

On August 20, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station facility. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:

• Radiation Monitoring Instrumentation

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

• Radioactive Material Processing and Transportation

• Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one self-revealing non-cited violation of very low safety significance (Green). However, because of its very low safety significance and because the finding was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section V1.A of the NRC Enforcement Policy. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Wolf Creek Generating Station facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection

Wolf Creek Nuclear Operating Corporation -2-in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Docket: 50-482 License: NPF-42

Enclosure:

NRC Inspection Report 05000482/2004008 w/attachment: Supplemental Information

REGION IV==

Dockets: 50-482 Licenses: NPF-42 Report: 05000482/2004008 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, Kansas Dates: August 16 - 20, 2004 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Louis C. Carson II, Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Daniel R. Carter, Health Physicist, Plant Support Branch Approved By: Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000482/2004-08; Wolf Creek Generating Station; Radioactive Material Control Program

The report covered a one week period of inspection on site by a team of four region-based health physics inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process, (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Cornerstone: Public Radiation Safety

Green.

The team reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1 that resulted from the licensees failure to properly control items contaminated with radioactive material. Three snubbers with fixed contamination levels ranging from approximately 1500 to 3000 disintegrations per minute were released from the radiological controlled area, but remained in the protected area. The licensee was alerted to the situation when a personnel radiation monitor in the secondary access area alarmed because of the presence of one of the snubbers. The finding was entered into the licensees corrective action program as Performance Improvement Request 2003-2438.

The finding was more than minor because it was associated with the cornerstone attribute (material release) and it affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain). The finding is of very low safety significance because (1) the finding was a radioactive material control issue (2) it was not a transportation issue, and (3) it did not result in a dose to the public greater than 0.005 rem. This finding also had crosscutting aspects associated with human performance (Section 2PS3).

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area

• Self-assessments and audits

• Corrective action program reports since the last inspection

• Calibration expiration and source response check currency on radiation detection instruments staged for use

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee Event Reports

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies The inspector completed 9 of the required 9 samples.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual (ODCM), and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, self-assessments, and audits

• Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, release permits, and dose projections of radioactive liquid and gaseous effluent

• Abnormal releases

• Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection

• Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control

• Interlaboratory comparison program results

• Audits, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports and special reports The inspector completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection (Engineering Design Package 09337, Liquid Radwaste Zero Filtration System),and current processes for transferring radioactive waste resin and sludge discharges

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting

• Shipping records for non-excepted package shipments

• Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Shipment packaging

• Licensee event reports or special reports The inspector completed 6 of the required 6 samples.

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program (71122.03)

a. Inspection Scope

This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I, the ODCM, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed

• Annual environmental monitoring reports and licensee event reports

• A sampling of air sampling stations and thermoluminescence dosimeter (TLD) monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement

• Significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits

• Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records.

• Audits, self-assessments, and corrective action reports performed since the last inspection.

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports and special reports The inspector completed 10 of the required 10 samples.

b. Findings

Introduction.

The team reviewed a Green, non-cited violation of Technical Specification 5.4.1 that resulted from the licensees failure to properly control radioactive material.

Description.

On August 15, 2003, one of the licensees workers attempted to remove a snubber from the protected area by way of the secondary access point. The snubber had previously been released from the radiological controlled area. Before the worker could remove the snubber, a personnel radiation monitor alarmed because of the presence of radioactive material.

Radiation protection personnel responded and performed radiation surveys. The surveys identified fixed contamination on the snubber of approximately 150 net counts per minute (or 1500 disintegrations per minute, assuming a 10 percent instrument efficiency). This event prompted the licensee to conduct additional surveys of snubbers previously removed from the radiological controlled area and stored in a warehouse within the protected area. The licensee identified two other snubbers with fixed contamination levels as high as 300 net counts per minute disintegrations per minute (or 3000 disintegrations per minute, assuming a 10 percent instrument efficiency.) The team concluded that snubbers were not surveyed adequately when they were released from the radiological controlled area. The occurrence was documented in the corrective action program as Program Improvement Request 2003-2438.

Analysis.

The failure to control radioactive material is a performance deficiency. The finding was more than minor because it was associated with the cornerstone attribute (material release) and it affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain). The finding is of very low safety significance because

(1) the finding was a radioactive material control issue

(2) it was not a transportation issue, and

(3) it did not result in a dose to the public greater than 0.005 rem. This finding also had crosscutting aspects associated with human performance in that licensee personnel failed to implement the established survey requirements designed to prevent the release of radioactive material.

Enforcement.

Technical Specification 5.4.1 requires that procedures listed in Regulatory Guide 1.33, Appendix A, be established, implemented and maintained. Section 7e. lists procedures for the control of radioactivity. Procedure RPP 02-515, Release of Material from the RCA, Revision 14, Section 9.2.2, require that tools, equipment, and scrap be smeared for loose contamination, frisked for fixed contamination, and compared to the release criteria. The licensee violated this requirement when it failed to survey the snubbers as required and subsequently released radioactive material from the radiological controlled area. Because the failure to control radioactive material was determined to be of very low safety significance and has been entered into the licensees corrective action program as Performance Improvement Request 2003-2438, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000482/2004008-01, Failure to control radioactive material.

4OA2 Problem Identification and Resolution

Annual Sample Review

a. Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation Monitoring Instrumentation (Section 2OS3)

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)

• Radioactive Material Processing and Transportation (Section 2PS2)

• Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)

b. Findings and Observations

No findings of significance were identified.

4OA4 Cross-Cutting Aspects of Findings

Section 2PS3 describes an issue with a human performance cross-cutting aspect which involved the failure of workers to follow programmatic requirements to control items contaminated with radioactive material.

4OA6 Management Meetings

Exit Meeting Summary

On August 20, 2004, the team presented the inspection results to Ms. D. Jacobs and other members of your staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

L. Aiken, Health Physics Technician, Radiation Protection

M. Brinkmeyer, Technician, Support Engineering

B. Copeland, Engineering Technician, Support Engineering

S. Devena, Senior Engineer, Systems Engineering

D. Gibson, Health Physics Technician, Radiation Protection

D. Jacobs, Vice President - Operations and Plant Manager

T. Just, Master Technician, Chemistry

M. Kerving, Health Physics Supervisor, Radiation Protection

S. Koenig, Manager, Chemistry/Radiation Protection

C. Medency, Health Physics Supervisor, Radiation Protection

W. Muilenburg, Engineer, Regulatory Affairs

L. Rice, Health Physics Technician, Radiation Protection

J. Truelove, Supervisor, Chemistry

NRC

F. Brush, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Opened and Closed During this Inspection NCV

05000482/2004008-01, Failure to control radioactive material.

Previous Items

Closed

NONE