ML20151N932
| 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: |
| 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
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Inspector:
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g R. E. Baer, Senior Radiation Specialist
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Facilities Radiological Protection Section
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Approved:
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B. Murray, Chief, Facilities Radiological
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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
- 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
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
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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.
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7.
Radioactive Waste Management (84850)
The NRC inspector reviewed the licensee's program for disposal of
low-level radioactive waste (LLRW) including:
management controls,
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quality control program, manifests, classification, form and
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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
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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
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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
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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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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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ATTACHMENT 1
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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, Revision 3, dated January 21, 1988
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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
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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,
1987
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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