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Insp Rept 50-482/87-12 on 870518-22.Violation Noted:Site Health Physicist Did Not Meet or Exceed Qualifications of Reg Guide 1.8.Deviation Noted:Licensee Did Not Possess Continuous Airborne Radioactivity Monitors
	ML20234D442
Person / Time
Site:	Wolf Creek
Issue date:	06/26/1987
From:	Baer R, Murray B, Scott H; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20234D368	List: ML20234D364; ML20234D376; ML20234D387; ML20234D442;
References
	RTR-REGGD-01.008, RTR-REGGD-1.008 50-482-87-12, IEIN-79-07, IEIN-79-7, IEIN-82-18, IEIN-82-43, IEIN-83-05, IEIN-83-25, IEIN-83-5, IEIN-83-59, IEIN-83-73, IEIN-84-24, IEIN-84-56, IEIN-84-61, IEIN-84-91, IEIN-85-048, IEIN-85-088, IEIN-85-48, IEIN-85-88, IEIN-86-022, IEIN-86-032, IEIN-86-22, IEIN-86-32, NUDOCS 8707070209
	Download: ML20234D442 (8)
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APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/87-12 License: NPF-42

Docket: 50-482

Licensee: Wolf Creek Nuclear Operations Corporation (WCNOC)

P. O. Box 411

Burlington, Kansas 66839

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS Site, Burlington, Kansas

Inspection Conducted: May 18-22, 1987

Inspectors:

R.

R

E.' Bier, Radiation

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etialist, Facilities

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Radiological Protect' n Section

I A/ MAR 2m u Qe

H. L. S'cott, Radiati,p o Specialist, Facilities

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Radiological Proteta. ion Section j

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Approved: b (1md lAA4duA b S/O

B. Murr'ay, C6ief, Fac' ities Radiolog e Date '

Protection Section

Inspection Summary

Inspection Conducted May 18-22, 1987 (Report 50-482/87-12) i

Areas Inspected: Routine, unannounced inspection of the radiation protection

program including: organization and management controls; external occupational '

exposure control and personal dosimetry; internal exposure control and

assessment; control of radioactive materials and contamination, surveys, and

monitoring; facilities and equipment; and the licensee's actions concerning

certain NRC Inspection and Enforcement Information Notices (IEIN). ;

Results: Within the areas inspected, one violation and one deviation were

identified (violation, radiation protection manager qualifications,

paragraph 5; and deviation, airborne radioactivity monitors, paragraph 6).

8707070209 870630

PDR

O ADOCK 05000482

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DETAILS

1. Persons Contacted

WCNOC

F. T. Rhodes, Vice President, Nuclear Operations

G. D. Boyer, Plant Manager

L. F. Breshears, Health Physics (HP) Supervisor

H. M. Davis, HP Supervisor

D. M. Dullum, Engineer, Nuclear Operations Support (NOS)

A. A. Freitag, Manager, Nuclear Plant Engineering

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

E. C. Holman, HP Technician

J. M. Isom, HP Technician

C Kesinger, Training Program Coordinator (HP)

W. H. Ketchum, Radiological Services Lead Engineer

L. M. Kline, HP Technician

W. M. Lindsay, Supervisor, Quality Systems

0. L. Maynard, Manager, Licensing

G. A. McClelland, QA Auditor

C. M. Medenciy, HP Supervisor

M. H. Megehee, Compliance Engineer

T. S. Morrill, Site Health Physicist

J. R. Myer, Senior Engineer NOS

M. M. Nichols, Superintendent, Plant Support

L. W. Nilges, HP Technician

D. K. Parks, Training Coordinator

G. J. Pendergrass, Licensing Engineer

L. T. Rice, HP Technician

W. J. Rudolph II, Manager, QA

W. L. Selbe, Lead Engineer NOS

R. M. Stambaugh, Supervisor, Audits, QA

K. M. Thrall, Radiological Services Senior Engineer

M. G. Williams, Superintendent, Regulatory, Quality and_ Administration l

N.R_C

B. L. Bartlett, NRC Resident Inspector

J. E. Cummins, NRC Senior Resident Inspector

Denotes those individuals present during the exit interview conducted on

May 22, 1987.

The NRC inspectors also interviewed several other licensee employees

including administrative, HP, and chemistry personnel. )

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2. Inspector Observations

The following are observations the NRC inspectors discussed with the

licensee during the exit interview on May 22, 1987. These observations

are not violations, deviations, unresolved items, or open items. These

observations were identified for licensee consideration for program

improvement, but the observations have no specific regulatory requirement.

The licensee stated that these items would be considered.

Radiation Survey Instrumentation - The NRC inspectors noted that a large

number of the portable radiation monitoring instrumentation were not I

available to support plant operation. This equipment was either out-of

service because the calibration had expired or was in need of repair.

Emergency Locker Equipment - Radiological monitoring equipment contained

in emergency kits are not removed and exchanged when their calibration

expires prior to the next scheduled inventory.

3. Program Areas Inspected

The following program areas were inspected. Unless otherwise noted, the

inspection was completed and revealed no violations, deviations,

unresolved items, or open items. Notations after a specific inspection

item are used to identify the following: I = item not inspected or only

partially inspected; V = violation; D = deviation; U = unresolved item;

and 0 = open item.

Procedure Inspection Requirements

83722 Organization and Management Controls (Radiation Protection)

02.01 - Organization

02.02 - Staffing

02.03 - Radiation Protection Manager - V (see paragraph 5)

02.04 - Identification and Correction of Program

Weaknesses - I i

02.05 - Audits and Appraisal

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83524 External Occupational Exposure Control

and Personal Dosimetry ;

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02.01 - Physical Controls j

02.02 - Administrative Controls j

02.03 - Personal Dosimetry 1

83724 External Occupational Exposure Control

and Personal Dosimetry i

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02.01 - Audits and Appraisal l

02.02 - Program Changes

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02.03 - Planning and Preparation for Outages

02.04 - Personal Dosimetry ;

02.05 - Administrative Controls

02.06 - Records, Reports, and Notifications

83525 Internal Exposure Control and Assessment

02.01 - Administrative Controls '

02.02 - Engineering Controls - I

02.03 - Respiratory Protection Equipment - I ;

02.04 - Air Sampling - I j

02.05 - Bioassay - I

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83725 Internal Exposure Control and Assessment

02.01 - Audits and Appraisals

02.02 - Program Changes l

02.03 - Planning and Preparation for Outages - I

02.04 - Assessing Intakes of Radioactive Materials - I

02.05 - Engineering Administrative Controls - I

02.06 - Respiratory Protection Equipment - 1

02.07 - Records, Reports, and Notifications

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83526 Control of Radioactive Materials and Contamination,

Surveys, and Monitoring i

02.01 - Area and Airborne Radiation Monitors - D (see

paragraph 6)

02.02 - Portable Survey, Sampling, and Contamination

Monitoring Instruments

02.03 - Protective Clothing and Equipment

02.04 - Radioactive Material and Contamination Control j

02.05 - In-Plant Surveys and Monitoring j

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83726 Control of Radioactive Materials andContamination, 3

Surveys, and Monitoring i

1

02.01 - Audits and Appraisals

02.02 - Program Changes

02.03 - Surveys and Monitoring

02.04 - Radioactive Materials and Contamination Controls

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83527 Facilities and Equipment

02.01 - Facilities

02.02 - Equipment

83727 Facilities and Equipment

02.01 - Facility Changes

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4. Review of NRC Inspection and Enforcement Information Notices

The NRC inspectors reviewed the licensee's program for reviewing and

tracking information contained in certain IEINs. The licensee's nuclear

operations support group tracks IEINs and other information in accordance

with Procedure KGP-1311, " Industrial Technical Information Program."

The licensee's responses to the following IEIN's were reviewed:

79-07 79-09 80-22 81-26

82-18 82-31 82-36 82-42

82-43 82-44 82-49 82-51

83-05 83-10 83-14 83-21

83-25 83-33 83-49 83-52

83-59 83-64 83-67 83-68

83-73 83-81 84-15 84-19

84-24 84-34 84-40 84-50

84-56 84-57 84-59 84-60

84-61 84-72 84-75 84-82

84-91 85-06 85-42 85-46

85-48 85-52 85-60 85-87

85-88 85-92 86-18 86-20 ;

86-22 86-23 86-24 86-30 J

86-32 86-41 86-42 86-43

86-44 86-46 86-76 86-90

86-103 86-107 87-03 87-07

The licensee's actions were generally considered acceptable. The NRC

inspectors discussed with licensee representatives that some IEINs involve

incidents which could involve more than one work group within the

licensee's organization. However, procedures have not been established

for these types of incidents.

No violations or deviations were identified.

5. Radiation Protection Manager Qualifications

The NRC inspectors reviewed the qualifications of the individual recently

assigned to the position of Site Health Physicist.

Technical Specification 6.3.1 states "each member of the unit staff shall

mee't or exceed the minimum qualifications of ANSI /ANS 3.1-1978, except for

the Site Health Physicist who shall meet or exceed the qualifications of

Regulatory Guide 1.8, September 1975 for a Radiation Protection Manager."

Regulatory Guide 1.8, September 1975 states, in part, the Radiation

Protection Manager (RPM) should be an experienced professional in applied

radiation protection at nuclear facilities dealing with radiation

protection problems and programs similar to those at nuclear power

stations. The RPM should have a Bachelor's Degree or the equivalent in a

science or engineering subject, including some formal training in

Rad 4ation Protection. The RPM should have at least 5 years of-

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professional experience in applied radiation protection and at least.3

years of this professional experience should be in applied radiation

protection work in a nuclear facility dealing with radiological problems

similar to those encountered in nuclear power stations, preferably in an

actual nuclear power station.

The NRC inspectors reviewed the personal resume and discussed work

assignments with the individual designated as the Site Health Physicist.

The NRC inspectors concluded that the individual had accumulated

experience which totaled approximately 3 years in applied radiation

protection and the equivalent of a bachelors degree.

The failure to designate an individual as the Site Health Physicist that

meets or exceeds the requirements of Regulatory Guide 1.8, September 1975

is considered an apparent violation of Technical Specification 6.3.1.

(482/8712-01)

6. Airborne Radioactivity Monitoring

The NRC inspectors reviewed the licensee's airborne monitoring program to

determine agreement with Sections 12.3.4.2.2.2.9 and 12.5.2 1 of the USAR.

The USAR states that work areas will be monitored using portable

continuous airborne monitors (CAMS) as a primary method, with grab

sampling as a backup to the CAMS. In addition, the licensee stated in

their April 22, 1986, letter in response to deviation (482/8542-01) that

CAMS would be utilized to sample the following locations:

1974' Auxiliary Building

2000' Auxiliary Building (north end)

2000' Auxiliary Building (south end)

1976' Radwaste Building

2047' Fuel Building

The NRC inspectors determined on May 20, 1987, the licensee did not have

CAMS sampling: (1) the 2000-foot level in the auxiliary building (north

end), (2) the 1976-foot level in the radwaste building, and (3) the

2047-foot level in the fuel building. The failure to implement the

specified airborne monitoring program is considered a deviation from -

commitments made to the NRC. (482/8712-02)

7. personnel Dosimetry

The NRC inspectors reviewed the licensee's personnel dosimetry program.

The licensee's primary, in-house, system is a Panasonic Thermoluminescent

Dosimeter (TLD) system. The licensee uses four TLD elements, two

(elements 1 and 2) are lithium borate and two (elements 3 and 4) calicum

sulfate in a type VD802 dosimeter. The filtration over the four elements

of the dosimeter is as follows:

a . .

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Element Filtration (milligrams per square

Number centimeter)

1 23 (mylar)

2 300 (plastic)

3 300 (plastic)

4 1000(plastic, lead) l

The licensee's quality assurance / quality control program includes the use

of spiked quality control badges which are read with each tray containing

50 badges. Each month, approximately 15 spiked badges are also processed

which have been exposed to beta and gamma radiations, neutron radiation,

or gamma radiation. The radioactive sources used to spike these badges

are strontium-90, cesium-137, and moderated californium-252.

The licensee had a contractor conduct a neutron and photon dose and energy I

spectral measurement inside the reactor containment during 50 percent and

100 percent power operation. It was concluded that the remmeter and ]

albedo TLDs used were energy dependent in that they yield a higher j

response per unit flux at lower neutron energies (less than 10 key) than i

at higher energies. The overresponse for the remmeter was approximately

2.5 and the overresponse to the albedo TLD was typically a factor of 6 at

100 percent power and 17 at 50 percent power.

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No violations or deviations were identified.

8. Skin Contamination / Hot Particles

The inspector reviewed the licensee's prograrr for documenting skin and

clothing contamination and the operation of laundry facilities including

monitoring of protective clothing. Procedures HPH 03-014 " Personnel

Decontamination," Revision 1, December 23, 1985, and HP 03-005 " Laundry

Facility Operation," Revision 0, November 16, 1984, have been implemented

to address the above areas.

The NRC inspectors discussed with licensee representatives the information

discussed in IEIN 86-23, " Excessive Skin Exposure Due to Contamination with

Hot Particles." The licensee utilizes friskers at the step-off pad leaving

contaminated areas and a personnel contamination monitor when exiting the

radiologically controlled area. Protective clothing is monitored for

fixed contamination and clothing having fixed contamination greater than

0.5 mr/hr is segregated. The NRC inspectors noted in procedure HPH 03-014

that the licensee does not routinely provide for a determination of skin

dose from contamination unless personnel contamination is greater than

100 counts per minute above background for longer than one hour nor are

there any directions for the removal and identification of the contamination

if it is a small area (particle).

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The licensee stated that they plan to review and upgrade i

procedure HPH 03-014 to ensure the information in IEIN is adequately j

addressed. '

No violations or deviations were identified.

9. Exit Interview

The NRC inspectors met with the personnel identified in paragraph 1 at the

conclusion of the inspection on May 22, 1987. The NRC inspectors

summarized the scope and findings of the inspection.

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ML20234D442

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