IR 05000482/1985020

Insp Rept 50-482/85-20 on 850423-26,30 & 0501-03.No Violation or Deviation Noted.Major Areas Inspected:Radwaste Program,Including Gaseous,Liquid & Solid Radwaste & Air Cleaning

ML20126H880
Person / Time
Site:	Wolf Creek
Issue date:	06/10/1985
From:	Baer R, Martin L, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20126H857	List: IR 05000482/1985020 ML20126H854
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-482-85-20, NUDOCS 8506180465
Download: ML20126H880 (9)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: STN 50-482/85-20 Operating License: NPF-32 Docket: STN 50-482 Licensee: Kansas Gas and Electric Company (KG&E)

P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS Site, Burlington, Kansas Inspection Conducted: April 23-26, 30, and May 1-3, 1985 Inspector: MV d8 R. 4. Baer, Radiation Specialist, Facilities D(te

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Radiological Protection Section Approved: / A/AO;MMd///L b b BTarne Murr&y, " Chi'ef, acilities Radiological D&te'

Protection Section

//) A # Af L. E. Martin, G#iief, Project Section A

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gatg Reactor Pro;4ct Branch 2

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8506180465 850613 PDR ADOCK 05000482 O PDR

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-Inspection Summary Inspection Conducted April-23-26, 30, and May 1-3, 1985 (Report STN 50-482/85-20)

Areas Inspected: Routine, announced inspection of the licensee's radioactive waste program including: gaseous radwaste, liquid radwaste, solid radwaste, air cleaning, and radiation monitoring systems. The inspection involved 66 inspector-hours onsite by one NRC inspecto .

Results: Within the 5 areas inspected, no violations or deviations were identified. Three open items involving gaseous radwaste system representative sampling, process monitor calibration, and process and effluent monitor calibration procedures were identified (paragraph 4).

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-3-DETAILS Persons Contacted KG&E

• F. T. Rhodes, Plant Manager

• C, C. Mason, Director Nuclear Operations

• G. D. Boyer, Superintendent Technical Support G. R. Bramlett, Instrument and Calibration (I&C) Supervisor

• D. R. Byerley, Senior Instructor T. W. Coates, I&C Assistant Supervisor A. A. Freitag, Nuclear Plant Engineer J. C. Guimbellot, System Test Supervisor

• C. J. Hoch, Quality Assurance (QA) Technician

• J. M. Isom, Radwaste Coordinator D. J. Kinoshita, Operations Test Engineer

• W. M. Lindsay, Quality Systems Supervisor R. L. Logsdon, Site Chemist T. J. McFall, Nuclear Plant Engineer T. S. Morrill, Chemistry Supervisor

• M. M. Nichols, Site Health Physicist C. L. Palmer, Chemistry Supervisor

• L. E. Paulson, Corporate Radwaste Engineer

• K. R. Petersen, Licensing J. Robertson, I&C Technician R. Stadobcugh, QA Auditor

• C. A. Swar*.zendruber, Manager Radiological Services

• G. Williams, Regulatory, Quality and Administration Superintendent R. Wollum, I&C Coordinator Others W. D. Allen, Allen Nuclear Associates, Consultant

• B. L. Bartlett, NRC Resident Inspector H. F. Bundy, NRC Resident Inspector J. E. Cummins, NRC Resident Inspector R. Fell, Nuclear Reactor Regulation (NRR) Meteorology and Effluent Treatment Branch E. L. Geiger, Bechtel Mechanical Engineer Lead T.'E. Moskel, Bechtel Plant Facilities Designer P. W. O' Conner, NRR, Project Manager WCGS The NRC inspector also. interviewed other licensee and contractor employees including health physics, chemistry, operations, and test personne * Denotes those individuals present during the exit meeting on May 3, 1985.

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l 2. Licensee Action on Previously Identified Open Items (Closed) Open Item (482/8323-06): . Solid Radwaste Management - This item involved the lack of preoperational test procedures, representative sampling of resins, and an ALARA review of the installed system. The licensee had completed preoperational test procedures and tests on the ,

solid waste, filter handling, and resin transfer systems, verified representative sampling, and performed an ALARA review. This item is considered close (Closed) Open Item (482/8323-07): Air Cleanin.g Systems - This item involved the lack of preoperational test procedures. The licensee had developed preoperational test procedures and completed testing on all nine air cleaning systems. This item is considered close (Closed) Open Item (482/8323-08): Area Radiation Monitors - This item involved the lack of approved preoperational test, surveillance, calibration, and operational procedure The licensee had developed and approved procedures which addressed preoperational testing, surveillance, calibration, and operation of the area radiation monitoring system. This item is considered close (Closed) Open Item (482/6:23-09): process and Effluent Radiation Monitors - This item involved the lack of preoperational test procedures, determination of calibration sources, and issuance of surveillance, calibration, and operational procedures. The licensee had developed preoperational test, surveillance, calibration, and operational procedures, and established calibration sources for the process and effluent radiation monitors. This item is considered close (Closed) Open Item (482/8323-10): Technical Specifications - This item involved the lack of a process control program for solidification of radwaste. The licensee had developed a process control program for solidification of waste and received approval from NRR for implementatio This item is considered close (Closed) Open Item (482/8406-02): NUREG-0737, Item II.F.1-1, Noble Gas Monitor - This item involved the lack of calibration and operating procedures and training of personnel. The licensee had implemented calibration and operating procedures and provided training for shift chemistry personnel. This item is considered close (Closed) Open Item (482/8406-03): NUREG-0737. Item II.F.1-2, Sampling and Analysis of Plant Effluents - The licensee had resolved all of the NRC's concerns-regarding system evaluations, testing, and personnel training. This item is considered closed.

(Closed) Open Item (482/8406-04): NUREG-0737, Item II.F.1-3, Containment High Range Monitor - This item involved the lack of installation of the two required detectors and development of calibration procedures. The

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-5-licensee had installed and calibrated two high range containment monitor This item is considered close (Closed) Open Item (482/8425-29): Radwaste Laboratory and Sampling System - This item involved the lack of a complete and functional radwaste laboratory and sampling system for collecting and analyzing effluent liquid waste samples. The licensee had completed testing of the sampling system and the radwaste laboratory was operational. This item is considered close . Licensee's Action on Operating License NPF-32, Attachment 1 (Closed) License Condition 1.a.: The primary containment high range radiation monitors shall be source checked and calibrated (482/8406-04).

The licensee had source checked and electronically calibrated the two containment high range radiation monitors GT-RE-59 and GT-RE-60 as required. This item is considered close (Closed) License Condition 1.f.: Establish by test, the operability of process radiation monitors SJ-RE-01 (CVCS Letdown Monitor), GE-RE-92 (Condenser Air Discharge Monitor), and GH-RE-23 (Waste Gas Decay Tank Vent Monitor). The licensee had completed preoperational and calibration testing of the three process radiation monitors and demonstrated their operability. This item is considered close (Closed) License Condition 1.g.: Preoperational testing and calibration of area, process and effluent radiation monitors (482/8323-08, 09). The licensee had completed preoperational testing and calibration of all area, process-and effluent radiation monitors. This item is considered close . Open Items Identified During This Inspection Open items are matters that require further review and evaluation by the NRC inspectors or the licensee. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspecto ,

Open Item Description Paragraph 482/8520-01- Gaseous Radwaste System 5 Representative Sampling 482/8520-02 Calibration of: Process 9b Radiation Monitors 482/8520-03 Calibration Procedures for 9b Process and Effluent Monitors 5. Gaseous Radioactive Waste Management The NRC inspector reviewed the licensee's actions to resolve the NRC inspector's concerns regarding outstanding test deficiencies associated

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-6-with preoperational test SU3-HA01, " Gaseous Radwaste System," and verification of representative samplin The licensee had completed preoperation test procedures, preoperational testing, an ALARA review, and verified the tank volumes of major tanks used in the waste gas syste The licensee had not verified that the samples taken of gaseous effluent would be representative of the entire waste gas tank volum The licensee's representative stated that this verification would be performed within 6 months after the reactor had been operated and radioactive gases had been generated and collecte This is considered an open item (482/8520-01) pending verification by the-licensee that gaseous ef fluent samples are representative of the discharged volum The licensee was in the process of completing corrective action on Test Deficiency Reports (TDRs) generated during the preoperational test of the gaseous waste system. Two identified problems were associated with the hydrogen / oxygen analyzers and the hydrogen recombiners. As a result of the identified problems, the licensee was installing new controllers on the

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analyzers and a moisture separator on the recombiners. Open Item

'(482/8323-04) remains open pending completion of corrective actions on the analyzers and recocbiners and demonstration of their operabilit No violations or deviations were identifie . Liquid Radioactive Waste Managecent The NRC inspector reviewed the licensee's liquid waste management system to determine compliance with Final Safety Analysis Report (FSAR)

commi tment The licensee had developed and performed two preoperational tests, SU4-HB01, " Liquid Radwaste System," and SU4-HB02, " Waste Evaporator" of the liquid radioactive waste systems. Test deficiencies noted during the preoperational tests had been resolved. The licensee had also performed an ALARA review of the "as built" liquid radwaste system, developed a sampling program of clean and potentially contaminated liquid systems, and verified tank volumes and discharge flow rate The licensee had not completed testing to verify tank recirculation times and flush times for sample lines to assure representative sampling of effluents. Open Item (482/8323-03) will remain open pending completion of the representative sampling progra No violations or deviations were identifie ..

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l l-7- Solid Radioactive Waste System l The NRC inspector reviewed the solid radioactive waste system to determine l compliance with FSAR com::iiteents and Technical Specifications (TS).

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The NRC inspector reviewed the preoperational tests and procedures,

! SU4-HC01, " Solid Waste Systea," SO4-HC02, " Filter Handling System," and SU4-HCO3, " Resin Transfer," the licensee had conducted on the solid

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radioactive waste system. The inspector noted that the TDR generated during the conduct of these test had been resolved except for the

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transport of the filter cask. The spent filters are removed free the filter cubicles, placed in a transfer cask, and then lowered onto the ground floor of the radwaste building. The problem identified in the TDR involved the lack of a method of transporting the cask from the l ground floor to the radwaste solidification are The licensee could not

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transport the cask to the solidification are The NRC inspector also noted that during.the conduct of test SU4-HC01, the licensee was not able to demonstrate the structural stability requirement of 10 CFR Part 61.56(b).

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The licensee elected to utilize a vendor supplied portable solidification system for the solidification of evaporator bottoms, filters, and resin J l The licensee had not amended the FSAR to include the capability of

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transferring the evaporator bottoms and resins to a portable solidification system. This matter was previously discussed in NRC Inspection Report 50-482/83-23. The NRC inspector discussed with licensee representatives those elements that would be expected to be-addressed 'to

, satisfy TS 6.15.1 and the 10 CFR 50.59 safety analysis. The NRC

[. -inspector also stated that the licensee should review and consider the

. recocriendations of Regulatory Guide 1.143.

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l The licensee had received approval of the solid waste Process Control

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Program (PCP) from the NRC on April 17, 198 This approval was for the original installed solidification equipment and the process used in preoperational procedure SU4-HC01.

l The NRC inspector discussed with licensee representatives the elements needed to satisfy the requirements of TS 6.13, including the revision of the PCP to include the portable solidification process.

l No violations or deviations were identifie . Air Cleaning Systess The NRC inspector reviewed the licensee's air filtration system to determine cocpliance with FSAR comitment The licensee had completed preoperational testing, SU3-0006, "HEPA Filter / Charcoal Adsorber Test,"of all air cleaning systems. This test included ~ visual inspection of filter housing and ducts, airflow capacity and distribution, air-aerosol mixing uniformity test, inplace leak test of

HEPA filter banks, and inplace leak test of the charcoal adsorbers, e i

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-8-The NRC inspector reviewed the preoperational test package including the test results for the auxiliary / fuel building normal exhaust filter adsorber unit, condenser air removal filter adsorber unit, emergency exhaust filter adsorber unit, radwaste building exhaust filter adsorber unit, containment atmospheric control filter adsorber unit, containment purge filter adsorber unit, access control exhaust filter adsorber unit, control room filtration system filter adsorber unit, and control room pressurization system filter adsorber uni The NRC inspector noted that the calibration for the Freon generator (instrument number 83102-6) was due on January 18, 1985, and on January 23, 1985, charcoal testing was still in progres The licensee had also noted on TDR-003, that the test equipment calibration date had expired. The resolution of this TDR included the vendor providing a telex stating that the generator was verified as still in calibration. The NRC inspector noted that the vendor did not always record the instrumentation used to perform the test on the test data sheets and that the vendor test procedures are not included in the SU3-0006 test packag The NRC inspector expressed concern that: (1) the licensee had not included the calibration data showing the required reading, as found, and as left data for the Freon generator that was out of calibration; (2) the test data sheets did not include the instruments used to perform the test; (3) the vendor test procedures were not included in the test package so that the methodology used could be audited; and (4) no procedure was referenced which addressed the loading of charcoal into absorber filter trays and test canisters. The licensee stated that the necessary data would be incorporated in the SU3-0006 test packag The NRC inspector noted that the licensee was not able to test the second HEPA filter bank air distribution because the system design did not permit access to the filter bank. This same deficiency had been previously noted at the Callaway Plant which is similar in design as Wolf Cree No violations or deviations were identifie . Radiation Monitoring Instrumentation The NRC inspector reviewed the licensee's inplant radiation monitoring systems for compliance with the FSAR, NUREG-0737, and T Area Radiation Monitoring System The NRC inspector reviewed preoperational test procedure SU4-SD01,

" Fuel Building Area Radiation Monitors," and SU4-SD02, " Area Radiation Monitors (excluding fuel building)." The licensee had not provided for calibration over the full range of operation for the area radiation monitors during the preoperational test, but provided the NRC inspector with data sheets which demonstrated that full range calibration had been performed just prior to preoperational testin The NRC inspector reviewed procedure STN 1C-503, " Channel Calibration d

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-9-Radwaste Building Corridor Ground Floor Area Radiation Monitor SDRE04" which is typical of all area radiation monitor calibration procedures. Section 5.3 of STN IC-503 addresses full scale calibration of the radiation detector No violations or deviations were identifie Process and Effluent Radioactivity Monitoring System The NRC inspector reviewed preoperational test SU3-SP01, " Process Radiation Monitoring System." The test package contained a test deficiency, (TD) 012, which stated that testing was not performed on selected monitors not required for fuel load, and TDR-001 listed the 24 monitors not tested. At the time of this inspection, the licensee had performed preoperational testing of those monitors listed in TDR-001. The NRC inspector reviewed the tests and test results of 9 of the 24 monitors listed in TDR-001. Three of the nine test results reviewed, SJ-RE-01, "CVCS Letdown Monitor," GE-RE-92, " Condenser Air Discharge Monitor," and GH-RE-23, " Waste Gas Decay Tank Vent Monitor," had been listed in Attachment 1 to the facility operating license as required to be operational prior to initial criticalit The NRC inspector discussed with licensee representatives the fact that effluent monitors had been calibrated using radioactive gases with gaseous monitors and radioactive liquids with liquid monitors; however, the 24 process monitors listed in TDR-001 had only been calibrated with a single transfer source and electronic calibration methods. The licensee stated during the exit interview on May 3, 1985, they would calibrate the process monitors using radioactive gases and liquids within 6 months af ter issuance of the operating license. The inspector stated this would be considered an Open Item (482/8520-02)

pending completion of this calibratio The NRC inspector also discussed with licensee representatives the fact that calibration procedures for the process and effluent monitors did not address full range calibrations for each monitor although this was performed during the acceptance testing of the monitors. The licensee stated that calibration procedures would be revised to include full range, one point per decade calibrations and would be completed within 6 months after issuance of the operating license. The NRC inspector stated this would be considered an open item (482/8520-03) pending revision of the calibration procedure No violations or deviations were identifie . Exit Interview The NRC inspector met with licensee representatives identified in paragraph 1 at the conclusion of the inspection on May 3, 1985. The NRC inspector discussed the scope and findings of the inspection. The licensee committed to completion of the open items identified in paragraph 4 within 6 months after issuance of the operating licensee.