ML20151N932

Insp Rept 50-482/88-09 on 880314-18.Violation Noted.Major Areas Inspected:Solid Radwaste Program,Transportation Activities & Low Level Radwaste Storage Facilities

ML20151N932
Person / Time
Site:	Wolf Creek
Issue date:	04/11/1988
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151N900	List: ML20151N897 ML20151N908 ML20151N932
References
50-482-88-09, 50-482-88-9, NUDOCS 8804260046
Download: ML20151N932 (9)

See also: IR 05000482/1988009

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/88-09 Operating License: NPF-42

Docket: 50-482

Licensee: Wolf Credk Nuclear Operating Corporation (WCNOC)

P.O. Box 411.

Burlington, Kansas 66839

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS Site, Burlington, Kansas

Inspection Conducted: March 14-18, 1988

Inspector: _ / ~ // [

g R. E. Baer, Senior Radiation Specialist Date '

Facilities Radiological Protection Section

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Approved: / / fr

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B. Murray, Chief, Facilities Radiological Dare /

Protection Section

Inspection Summary

Inspection Conducted March 14-18, 1988 (Report 50-482/88-09)

Areas Inspected: Routine, unannounced inspection of the licensee's solid

radioactive waste program, transportation activities, and low-level radioactive

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waste storage facilities.

Results: Within the areas inspected, one violation was identified (failure to

lock a high radiation area, paragraph 6).

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DETAILS

1. Persons Contacted

WCNOC

• B. D. Withers, President

• G. D. Boyer, Plant Manager

• T. M. Damashek, Supervisor, Quality Surveillance

• C. M. Estes, Manager, Operations

J. D. Freeman, Radwaste Supervisor

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

• C. F. Kesinger, Training Program Coordinator (Health Physics (HP))

• E. Lehmann, Engineer, Technical Staff

• R. L. Logsdon, Site Chemist

• C. M. Medenciy, HP Supervisor, Radwaste

• B. McKinney, Manager, Technical Support

• J. F. McMahon, Supervisor, Technical Training

• T. S. Morrill, Site HP

• C. E. Parry, Manager, QA

• C. G. Patrick, Supervisor, Quality Systems

• G. J. Pendergrass, Licensing _ Engineer

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Williams, Manager, Plant Support

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Zell, Manager, Nuclear Training

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• B. L. Bartlett, Senior Resident Inspector

A. W. Grella, Office of Nuclear Material Safety and Safeguards (NMSS)

M. E. Skow, Resident Inspector

D. M. Sollenberger, NMSS

• Denotes those individuals present at the exit interview on March 18, 1988.

2. Licensee Action on Previously Identified Inspection Findings

(Closed) Violation (482/8717-01): Failure to Provide Radwaste Retraining

- This item was identified in NRC Inspection Report 50-482/87-17 and

involved the failure to provide radwaste retraining to the HP

supervisor-radwaste. The licensee provided retraining in November 1987 in

the NRC/ Department of Transportation (D0T) regulations, transportation

requirements, and burial site license criteria.

(Closed) Violation (482/8717-02): Failure to Maintain HP Training Records

- This item was identified in NRC Inspection Report 50-482/87-17 and

involved the failure to maintain complete up-to-date records of training

activities. The licensee had updated the training records to include the

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missing training courses for the individuals concerned.

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3. Inspector Observations

The following are observations the NRC~ inspector discussed with the

licensee. These observations are neither violations nor unresolved' items.

These items were recommended for licensee consideration for program

improvement, but they have no specific regulatory requirement. The

licensee indicated that these items would be reviewed.

Training Records - The licensee computer printout of an individual's

training history provides a course code number, but no description of

the course. See paragraph 5 for additional. details.

Use of Temporary Hose - The licensee uses long lengths of temporary

hose for transferring radioactive spent resins, evaporator bottoms,

and radioactive liquids to the portable demineralizer and the high

integrity containers (HIC) in preparation for shipment of radicactive

waste. See paragraph 6 for additional details.

Shipping Cask Users Manual - The licensee did not maintain a working

copy of the users manual for casks being used to ship radioactive

waste in the radwaste supervisors /HP supervisor-radwaste office. See

paragraph 8 for additional details.

Shipping Document Checklist - The licensee did not provide a shipping

docue nt or supervisor's review checklist for radioactive

material /radwaste packages. See paragraph 7 for additional details.

4. Organization and Management Controls-Radwaste (83722/83522}

The NRC inspector reviewed the licensee's staff functional assignments

including: organization, responsibilities, authorities, staffing,

identification and correction of weaknesses, audits and appraisals,

communication to employees, and documentation and implementation relating

to solid radioactive waste and transportation programs to determine

compliance with NRC Bulletin 79-20 and Technical Specification (TS)

Sections 6.22 and 6.5, and commitments in Chapters 13.1 and 13.4 of the

Updated Safety Analysis Report (USAR).

The NRC inspector reviewed those procedures and documents listed in

Attachment 1.

The NRC inspector noted that the licensee's procedures, which appear

adequate for regulatory compliance, could contain additional information

to provide a better working document, such as in Procedure HP 09-505,

Section 4.3 which states, "Perform a general survey of the item (s) to be

packed to determine radiation levels for proper placement inside the

container. Note: Care must be taken to ensure that area postings are not

violated and the container will not exceed D0T requirements." The

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licensee did not state what the 00T requirements were or the applicable

D0T paragraph (173.441) that applied.

No violations or deviations were identified,

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5. Training and Qualifications-Radwaste (83723/83523)

The NRC inspector reviewed the licensee's training program including:

' adequacy of training, employee knowledge, qualification requirements, new

employees, INP0 accreditation, audits and appraisals, training not covered

by INP0, and transportation /radwaste training for personnel involved in

the transportation of radioactive material and solid radioactive waste

activities to determine compliance with the requirements of NRC

Bulletin 79-20 and TS Section 6.4, and commitments in Chapter 13 of the

USAR.

The NRC inspector discussed with licensee representatives the computer

printout of individual training records. The present printout provided

the course code, date completed, and grade information, but without a

course code book it is not possible to determine what each entry

references. The time required to determine the training a single

individual received could require between 1/2 to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, which does not

include reviewing the specific course lesson plan. The licensee

acknowledged the training printout was not user friendly and agreed that

changes would be made to assist in the auditing of training records.

The NRC inspector reviewed lesson plans for training provided and select

training records of personnel in operations, maintenance, quality control,

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and HP who are assigned to radioactive waste processing and transportation

activities. The NRC inspector reemphasized that the training requirements

as specified in NRC Bulletin 79-20 are applicable to all individuals who

are involved in the transfer, packaging, and transport of radioactive

material and this training should be received prior to the individuals

involvement in these activities.

No violations or deviations were identified.

6. Solid Radioactive Waste (84722/84522)

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The NRC inspector reviewed the licensee's solid radioactive waste program

including: processing and storage; audits and appraisals; program

changes; construction and installation of solid waste system; liquid

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leakage, overflow, and spillage; sampling; preoperational test program;

completion of preoperational test; procedures; disposition of low-level

waste; and installation, calibration, and testing of process monitors to

determine compliance with commitments in Chapter 11 of the USAR.

The NRC inspector discussed with licensee representatives the prolonged

use of temporary rubber hose used to connect the permanent radwaste

transfer piping system to tLe HIC, dewatering equipment and portable

demineralizer skid. The licensee does not perform any periodic testing or

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have a preventative maintenance program to ensure hose integrity. The NRC

inspector noted that the hose used to transfer spent resin is run through

a drain trough, which affords protection to the hose and would help

contain a leak, most of the way to the dewatering equipment.

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The NRC inspector determined that the licensee submitted and received

approval for their process control program (PCP) on April 17, 1985, and

the current PCP, Revision 4, had been included in the Semiannual

Radioactiva Effluent Release Report for July 1 through December 31, 1986,

as required by TS 6.13.1 and 6.13.2.

TS 6.12.2 requires that areas accessible to personnel with radiation

levels greater than 1000 mrem /hr at 18 inches from the radiation source

shall be provided with locked doors to prevent unauthorized entry.

The NRC inspector determined during a routine inspection of the radwaste

building on March 17, 1988, that room 7225, the low-level drum storage

area, located on the 2000-foot elevation of the Radwaste Building

contained the Duratek portable demineralizer skid in the northeast corner

of the room. This area was not provided with locked doors to prevent

unauthorized entry. The demineralizer skid was a posted high radiation

, area with barrier rope and a flashing light installed on the southwest

corner of the skid shield. The room also was a posted high radiation area

at the sliding door which is routinely left in the open position because

of mechanical problems with the opening / closing system. The highest

recorded radiation level within the room was 40 mrem /hr on the March 10,

1988, weekly room survey. The latest radiological survey on the Duratek

demineralizer skid, February 24, 1988, indicated a radiation intensity of

3500 mrem /hr at contact and 1300 mrem /hr at 18 inches from a filter tank.

The NRC inspector discussed with licensee representatives that the failure

to provide locked doors was considered an apparent violation of TS 6.12.2

(482/8809-01). The licensee stated they considered this a large area and

conspicuously posting and a flashing light would meet the TS requirements.

The NRC inspector stated that the area could be locked at the sliding door

or an enclosure could be constructed around the individual area as

specified in the TS. The licensee later stated that a work request had

been submitted about 2 weeks prior to the NRC inspector's determination

for construction of an enclosure around the demineralizer skid.

l 7. Radioactive Waste Management (84850)

The NRC inspector reviewed the licensee's program for disposal of

, low-level radioactive waste (LLRW) including: management controls,

l quality control program, manifests, classification, form and

! characterization, shipment labeling, tracking of shipments, and disposal

site license conditions to determine compliance with the requirements of

10 CFR Parts 20.311, 61.55, and 61.56.

. The licensee uses the "radman" computer program for determinations of

l waste classification and managing the LLRW program. The NRC inspector

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noted that the licensee had updated the waste classification program in

November 1987 from waste stream samples analyzed by an approved vendor.

The licensee was not solidifying waste, spent resins were being dewatered

in a HIC and shipped to a burial site.

The NRC inspector reviewed the waste shipment document packages located at

both the HP supervisor-radwaste office and at records management. The NRC

inspector noted that these document packages were complete, but there was

not a checklist that indicated what documents were in each package or that

the package had received any supervisory review.

The NRC inspector reviewed the licensee's records for LLRW shipped since

1985. The following tabulation shows the total volume of LLRW shipped for

the period 1985 through 1987.

Year Volume - Cubic Feet Curie Content

1987 4504.3 11.521

1986 6102.3 144.368

1985 0 0

No violations or deviations were identified.

8. Transportation (86721)

The NRC inspector reviewed the licensee's prograni for transportation of

radioactive materials including: audits and appraisals, procedures,

procurement and lease of packaging, implementation of the transportation

program, and transportation incidents to determine compliance with the

requirements of 10 CFR Part 71.

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The NRC inspector determined the licensee was a registered user for all

packages used for the transport of radioactive material. The licensee

maintained a controlled copy of the certificate of compliance and users

manual in the document control room. The NRC inspector discussed with

licensee representatives the desirability to maintain a copy of the users

manual with the HP supervisor-radwaste. The users manual contains

specific information on: what items have to be inspected prior to use of i

the package, tests that need to be performed, and the last time gaskets

were replaced and tests performed. The manual also provides procedures to

perform these tasks. The licensee stated they would review the NRC

inspector's obser.ation and provide a copy of the users manual for those

cask routinely used for the HP supervisor-radwaste.

The licensee had not experienced any transportation incidents which caused

a reduction in the effectiveness of packaging since the previous

inspection.

No violations or deviations were identified.

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9. Transportation Activities (86740)

The NRC inspector reviewed the licensee's transportation activities

program including: management controls, training program, audits and

reviews, procurements and selection of packaging, quality assurance-

program, preparation of packages for shipment, delivery of completed

packages to carrier, receipt of packages, periodic maintenance of

packaging, and records and reports to determine compliance with the

requirements of 10 CFR Parts 20 and 71, and 00T Regulations 40 CFR

Parts 170-189.

No violations or deviations were identified.

10. Low-Level Radioactive Waste Storage Facility (65051)

The NRC inspector reviewed the status of the LLRW storage facility program

including: basis for construction, QA program, procedures for

construction, organization and staffing, training and qualifications,

procedures, and effluent monitoring for compliance with WCGS license

conditions and the recommendations of NRC Generic Letter 81-38, NRC

Circular 80-18, Regulatory Guide 1.143, and NUREG-0800.

The NRC inspector determined that the licensee had not completed an onsite

LLRW facility. The licensee had shipped approximately 2807 cubic feet of

radioactive waste the first 6 months of 1987 and only 1697 cubic feet the

second 6 months for a total of 4504 cubic feet. The licensee's present

facility appears adequate for the amount of waste presently generated and

routine shipments are made so that a large accumulation of LLRW is not

being maintained.

No violations or deviations were identified.

11. Exit Interview

The NRC inspector met with the licensee representatives denoted in

paragraph 1 at the conclusion of the inspection on March 18, 1988. The

NRC inspector summarized the scope of the inspection and discussed the

inspection findings,

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PROCEDURES AND DOCUMENTS REVIEWED

Procedures

ADM 02-013,-Radwaste Coordinator, Revision 1, dated March 11, 1986

ADM 03-950, Radioactive Waste Program, Revision 3, dated February 1,1988

ADM 04-023, Radioactive Releases, Revision 9, dated January 26, 1988

HPH 09-501, Manual Classification of Waste, Revision 4, dated August 5, 1986

HPH 09-502, Manual Curie Content Determination, Revision 3, dated August 5, 1986

HPH 09-503, Collection and Transfer of Radioactive Waste, Revision 3, dated

February 25, 1986

HPH 09-504, Packaging of Compactible Solid Waste, Revision 3, dated January 25,

1988

HPH 09-505, Packaging of Noncompactible Solid Waste, Revision 3, dated

January 23, 1988

HPH 09-506, Packaging of High Level Filters, Revision 2, dated February 12, 1986

HPH 09-507, Packaging of Wet Solid Waste, Revisioni 3, dated January 21, 1988

HPH 09-509, Marking, Labeling, and Storage of Radwaste Containers, Revision 1,

dated September 10, 1985

HPH 09-510, Handling of Cartridge Filters, Revision 6, dated May 22, 1986

HPH 09-511, Use of Drum Inspection Facility, . Revision 2, dated March 19, 1986

HPH 09-512, Incoming Vehicle Surveys, Revision 2, dated March 19, 1986

HPH 09-513, Outgoing Vehicle Surveys, Revision 2, dated March 31, 1986

HPH 09-514, Transport Vehicle Loading and Inspection, Revision 6, dated

February 26, 1988

HPH 09-520, Manual Determination of Shipment Type, Revision 2, dated August 5,

1986

HPH 09-521, Shipment of Limited Quantity Materials, Revision 1, dated

February 6,1986

HPH 09-522, Shipment of LSA Materials, Revision 1, dated January 28, 1986

HPH 09-523, Shipment of Type A Materials, Revision 1, dated January 28, 1986

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HPH 09-524, Exclusive Use Shipment of Type B or HRC Material, Revision 1, dated

February 14, 1986

HPH 09-525, Shipment of Empty Packages, Revision 3, dated June 10, 1987

HPH 09-530, Radioactive Materials Shipping Documents, Revision 3, dated June 10,

1987

HPH 09-531, Advance Notifications, Revision 2, dated February 19, 1988

HPH 09-532, Radwaste Reports, Revision 4, dated January 23, 1988

HPH 09-533, Use of Aqua-Set Absorbant, Revision 0, dated June 24, 1986

HPH 09-534, Waste Sampling Procedure, Revision 0, dated February 19, 1988

HPH 09-541, Bead Resin and Activated Carbon Dewatering Procedure for CNSI 14-215

or Smaller Liners, Revision 0, dated March 10, 1988

SYS HB-129, Vendor Liquid Radwaste Processing, Revision 0, dated September 17,

1987

SYS HC-227, Vendor Processing of Primary Resins and Concentrates, Revision 2,

dated April 22, 1987

WChP-02, Process Control Program, Revision 4, dated August 27, 1986

Vendor 10-1, System Operation, Revision 3, dated November 13, 1987

Veador 10-2, Adding Media, Revision 3, dated November 13, 1987

l Vendor 10-3, Sluicing Media, Revision 3, dated November 18, 1987

kerdr 10-4, Leak Check, Revision 3, dated November 13, 1987

Audits and Surveillance Reports

50140-K162, Audit - Radioactive Waste Management and Transportation Activities,

dated May 6, 1987

53359 S-1589, Surveillance, Duratek Waste Processing, dated October 28, 1987

53359 S-1513, Surveillance, Resin Transfer and Dewatering, dated December 29,

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53359 S-1522, Surveillance, Radioactive Waste Program Records, dated March 4,

1987

53359 S-1586, Surveillance, Ouratek Resin Spill, dated October 23, 1987