IR 05000482/1988002

Insp Rept 50-482/88-02 on 880119-22.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Radwaste Mgt Programs

ML20196F390
Person / Time
Site:	Wolf Creek
Issue date:	02/12/1988
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20196F385	List: IR 05000482/1988002 ML20196F381
References
50-482-88-02, 50-482-88-2, NUDOCS 8803030171
Download: ML20196F390 (13)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:' 50-482/88-02 Operating License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operations Corporation (WCNOC)

P.O.' Box 411 L

Burlington," Kansas 66839 Facility Name: Wolf Creek Genera' ting Station (WCGS)

Inspection At: WCGS Site, Burlington, Kansas Inspection Conducted: January 19-22, 1988 Inspector: 2/"///

B. Nicholas, Sehior Radiation Specialist Date acilities Radiological Protection Section Approved: h M MA4446/ &//h/N urray, Chief, Facilit[es Radiological D' ate '

Protection Section Inspection Summary Inspection Conducted January 19-22,- 1988 (Report 50-482/88-02)

Areas Inspected: Routine, unannounced inspection of the licensee's liquid and gaseous radioactive waste management program Results: Within the areas inspected, no violations or deviations were identifie $$hh

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-2-DETAILS Persons Contacted WCNOC B. D. Withers, President, WCN0C F. T. Rhodes, Vice President, Nuclear Operations

• G. Williams, Superintendent of Regulatory, Quality, and Administration G. D. Boyer, Plant Manager C. M. Estes, Superintendent of Operations

• R. D. Flannigan, Supervisor, Compliance

• C. W. Fowler, Supervisor, Instruments and Controls (I&C)

• J. D. Freeman, Radwaste Coordinator

• G. D. Freund, Engineering Specialist, I&C S. A. Henry, Primary Chemistry Supervisor

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

• W. M. Lindsay, Supervisor, Quality Systems

• R. L. Logsdon, Site Chemist

• J. F. McMahon, Supervisor, Technical Training

• R. W. Miller, Surveillance Coordinator T. S. Morrill, Site Health Physicist M. M. Nichols, Superintendent, Plant Support

• C. L. Palmer, Radwaste Chemistry Supervisor

• C. G. Patrick, Superintendent, Quality Evaluations

• G. J. Pendergrass, Licensing Engineer K. R. Peterson, Licensing Lead Engineer

• H. L. Stubby, Chemistry Training Program Coordinator NRC

• B. L. Bartlett, NRC Senior Resident Inspector, Wolf Creek

• Denotes those individuals present during the exit interview conducted on January 22, 1988

, Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit interview on January 22, 1988. 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 requirements. The licensee stated that the observations would be reviewe Liquid Effluent Monitor Setpoints - The licensee had risused a default monitor setpoint while preparing a liquid effluent release permi (See paragraph 5)

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-3- Condensate Storage Tank Analysis Results - The licensee had not consistently documented the results of radioactivity measurements performed on weekly samples. (See paragraph 5) Radiation Monitor Calibrations - The licensee did not have a procedure to transmit radiation monitor calibration data into the licensee's data base progra (See paragraph 5)

3. Organization and Management Controls (83522/83722)

The NRC inspector reviewed the licensee's organization, staffing, identification and correction of program weaknesses, audits and appraisals, communication to employees, and documentation and implementation of the chemistry / radiochemistry section (C/RS) to determine adherence to commitments in Chapter 13 in the Final Safety Analysis Report (FSAR) and the requirements in Section 6.2 in the Technical Specifications (TS).

The NRC inspector verified that the organizational structures of the WCGS i radwaste operations section and C/RS were as defined in the-FSAR and T '

The NRC inspector reviewed the licensee's management control procedures and position descriptions for the WCGS assignment of responsibilities for .

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the management and implementation of the WCGS radioactive waste effluent .

program (RWEP). The NRC inspector verified that the administrative control responsibilities specified in the WCGS procedures were being implemented. Selected documents listed in Attachment 1 to this report ,

were reviewe The NRC inspector reviewed the staffing of the radwaste operations section and C/RS and determined that both sections were fully staffed for shift ;

rotation. The licensee's C/RS staff, which manages the RWEP, has replaced L four technicians since the previous NRC inspection of this area in l November 1986. The NRC inspector noted that the C/RS personnel turnover had been approximately 25 percent in the past 14 months. The WCGS radwaste operations section and C/RS staffing was determined to be in accordance with licensee commitment l No violations or deviation were identifie . Training and Qualifications (83523/83723)

The NRC inspector reviewed the licensee's training and qualification program for C/RS personnel and nonlicensed radwaste operators responsible for the RWEP including: education and experience, adequacy and quality of training, employee knowledge, qualification requirements, new employees, Institute of Nuclear Power Operations accreditation, and audits and r appraisals to determine adherence to commitments in Chapter 13 in the FSAR and the requirements in Sections 6.3 and 6.4 in the T !

The NRC inspector reviewed the education and experience of the present C/RS staff responsible for the RWEP and verified that they met the t

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-4-required qualifications specified in the FSAR and T It was determined that the licensee had an adequately qualified staff to meet shift staffing requirement The NRC inspector reviewed the licensee's training program for C/RS personnel and nonlicensed radwaste operators, including a review of course descriptions, personnel training records, and qualification card The NRC inspector found that the licensee's training program was being implemented in accordance with WCGS procedures, k

The NRC inspector reviewed individual staff training records and qualification cards for selected C/RS personnei and nonlicensed radwaste-operators responsible for performing RWEP activities. The NRC inspector verified that all shift qualified C/RS technicians and nonlicensed operators responsible for_ performing RWEP activities had completed the required training on the radiological effluent technical specifications (RETS), Offsite Dose Calculation Manual (0DCM), and radwaste systems to' perform liquid and gaseous effluent release No violations or deviations were identifie . Liquids and Liquid Wastes (84523/84723)

The NRC inspector reviewed the licensee's liquid radioactive waste effluent program including: liquid waste system construction and installation; liquid leakage, overflow, and spillage; liquid waste sampling; liquid process and effluent monitors; procedures for liquid waste and effluent systems; reactor coolant and secondary water quality; and audits and appraisals to determine adherence to commitments in Chapters 5, 9, and 11 in the FSAR and the requirements in Sections 3/4.3.3.10. 3/4.4.7, 3/4.11.1, 6.5, 6.8, and 6.15 in the T The NRC inspector reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, RWEP operating procedures, offsite dose results from liquid effluents, and functional checks and calibrations of equipment associated with the radioactive liquid waste processing system. Selected documents and records listed in Attachment 1 to this report were reviewe The NRC inspector reviewed current approved revisions of WCGS procedures governing the release of liquid. radioactive waste. These liquid effluent release procedures provide for the following: sampling of radioactive waste; chemical and radionuclide analyses prior to release; calculation of effluent release rates, projected offsite radionuclide concentrations, and offsite doses prior to release; recording effluent dilution parameters during releases; and verifying discharge flow rates and effluent volume discharged. Selected documents listed in Attachment 1 to this report were reviewe .

-5-The NRC inspector reviewed a representative number of liquid release permits for the period January 1987 through December 1987. It was determined that processing, sampling and analysis, and approval and performance of the releases were conducted in accordance with WCGS procedure Quantities of radioactive nuclides released in the liquid effluents were within the limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within the TS limit During the review of the liquid release permits, the NRC inspector observed that on radioactive liquid release permit 87200 the secondary ifquid discharge monitor (HF RE-45) high and low setpoints had been recommended to be set at 1.0E-02 uCi/ml and 1.0E-03 uCi/ml, respectivel The high alarm setpoint of 1.0E-02 uCi/ml was at the upper readout limit of the monitor and was at least two orders of magnitude less conservative than the pre-release calculeted setpoint of 5.1E-04 uCi/ml. This observation was discussed with the licensee during the inspection and it was determined that verbal-direction had been given to the C/RS tetonicians to set the monitor high setpoints at the upper readout limit of the monitor and the monitor low setpoint at one decade below that setpoint if the pre-release calculated setpoint was greater than the upper readout limit of the monitor providing a more conservative setpoint for release termination. The use of the upper readout limit of the monitor was misused in this one isolated case. A review of chemistry manual procedure CHM-02-150, "Use of the N06700 LRW/GRW System for Liquid Radioactive Release," Revision 5, April 29, 1987, indicated a caution in step 6.4.8 which allows a default setpoint value from chemistry manual procedure CHM-03-140, "Preparation of Radioactive Liquid Release Permits,"

Revision 4, April 29, 1997, to be used if the pre-release calculated monitor setpoint is less then 3.4 E-04 uCi/ml and the tritium concentration of the tank being released is less than 1.0 uCi/ml. The licensee had not written into the procedures listed above the verbal instruction which led to the misuse of a default value less conservative than the pre-release calulated setpoint. The NRC inspector discussed this observation and use of setpoint values other than the pre-release calculated values with the licensee's representatives during the exit interview on January 22, 1988, expressing the concern that either the pre-release calculated monitor setpoint be used or specific designated default setpoint values be satisfactorly explained in the respective procedures and the procedures provide specific guidance as to their us The licensee agreed to evaluate the use of default monitor setpoints and I take necessary corrective action to define their use when preparing a waste effluent release permi The NRC inspector determined that no design changes had been made to the liquid waste systems since the previous NRC inspection conducted in

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November 198 The NRC inspector reviewed procedures and selected reactor coolant and secondary water chemistry records for the period January 1987 through The records reviewed indicated that all required sampling

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l December 198 and analyses were performed at the frequencies required by the TS and the l analyses results met TS requirements. However, it was observed that on

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-6-numerous occasions the results of the weekly radioactivity analysis of the condensate storage tank had been recorded on Appendix 1, WCGS Technical Specification Surveillance Report, of Administrative Procedure ADM-04-230, Chemistry Surveillance Program, Revision 13, August 18, 1987, as "not

' applicable" rather than indicating no detectable radioactivity. This observation of inconsistent reporting of analysis results was discussed with the licensee's representatives during the exit interview on January 22, 1988. The licensee stated that the condensate storage tank had been routinely sampled and analyzed weekly and the results of each analysis in the future would be documented properly and consistentl The NRC inspector reviewed functional checks, calibrations, and setpoint procedures and records for radioactive waste liquid effluent monitors which showed that the frequency of functional channel checks and calibrations met TS requirements. The NRC inspector noted that the monitor calibrations were being performed using radioactive standards in the same media and configuration as the actual samples being measured in the effluent streams. The calibrations and monitor setpoint determinations were verified to have been performed according to approved procedure The NRC inspector reviewed surveillance test procedures and records to determine compliance with the radiation monitoring instrumentation calibrations. It was observed that the licensee did not have a procedure to transmit new monitor calibration data into the licensee's data base program (RM-80) after completing a radiation monitor calibration. The I&C surveillance test procedures for radiation monitor calibrations previously had steps requiring C/RS be notified that the monitor had been calibrated by the I&C section and was ready for the C/RS to complete the radiation monitor calibration using radioactive standards. The I&C surveillance tests also had required procedure step sign-offs when the C/RS had been notified and when the C/RS had completed their phase of the calibratio Recent procedure changes have deleted the required sign-offs by the C/RS and have been replaced by only one step indicating that I&C has notified the C/RS to complete the monitor calibration. The NRC inspector discussed these observations and concerns with the licensee during the inspection, and it was agreed by the licensee that procedural steps should be developed and incorporated into the C/RS surveillance test procedures for calibration of radiation monitor instrumentation which would officially transmit and enter all new radiation monitor calibration data into the RM-80 data bas The NRC inspector reviewed selected QA audit and surveillance procedures, audit and surveillance schedules for 1987 and the first and second quarters of 1988, and the qualifications of auditor Surveillances and audit reports of QA activities performed during 1987 in the area of radioactive waste effluent releases were reviewed for scope to ensure thoroughness of program evaluatio The NRC inspector also reviewed audits performed on contractors used to perform tests on the plant ventilation systems and verified that they have been approved and placed

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-7-on the qualified vendor supplier's lis The NRC inspector determined that the QA surveillances and audits had been performed in accordance with WCGS QA procedures and schedules and had not identified any significant problems. The documents which were reviewed are listed in Attachment 1 to this repor No violations or deviations were identifie . Gaseous Waste System (84524/84724)

The NRC inspector reviewed the licensee's gaseous radioactive waste effluent program including: gaseous waste system construction and installation, gaseous waste sampling, gaseous process and effluent monitors, procedures for gaseous waste and effluent systems, air cleaning systems, and audits and appraisals to determine adherence to commitments in Chapters 9, 11, and 17 in the FSAR and the requirements in Sections 3/4.3.3.11, 3/4.7.7, 3/4.11.2, 6.5, 6.8, and 6.15 in the T The NRC inspector reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits, analytical results, sampling requirements, surveillance tests, RWEP operating procedures, offsite dose results from gaseous effluents, and functional checks and calibrations of equipment associated with the radioactive gaseous waste processing syste Selected documents and records listed in Attachment 1 to this report were reviewe The NRC inspector reviewed current approved revisions of WCGS procedures governing the release of gaseous radioactive waste. These gaseous effluent release procedures provide for: the sampling of gaseous radioactive waste; radionuclide analysis prior to release; calculation of effluent release rate, projected offsite radionuclide concentrations, and offsite dose prior to release; verification of gaseous effluent radiation monitor setpoints and testing of effluent isolation valves prior to release; recording of meteorological conditions during releases; and verifying discharge flow rates and effluent volume discharged. Selected documents and records listed in Attachment 1 to this report were reviewe The NRC inspector reviewed selected gaseous waste release permits which included plant stack continuous releases and batch releases from waste gas decay tanks and containment for the period January 1987 through December 1987. It was determined that gaseous waste releases were performed according to procedure and the quantities of gaseous radionuclides released were within the limits specified in the RET Offsite doses had been calculated according to the ODCM and were within the TS limit The NRC inspector determined that no design changes had been made to the gaseous waste system since the previous NRC inspection conducted in November 1986, t

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-8-The NRC inspector reviewed functional checks, channel checks, calibrations, and setpoint procedures and records for gaseous radioactive waste effluent monitors and verified that the frequency of the various checks and calibrations met TS requirements._ The monitor calibrations and setpoint

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determinations were verified to have~been performed according to approved procedure The NRC inspector reviewed the licensee's procedures and surveillance tests for maintenance and testing of air cleaning systems which contain high efficiency particulate air (HEPA) filters and activated charcoal adsorber The NRC inspector verified that the licensee's procedures and surveillance tests provided.for the required periodic functional checking of ventilation system components, evaluation of HEPA and activated charcoal adsorbers, tracking of system operating hours, and replacement and in place testing of filter system No violations or deviations were identifie . Reports of Radioactive Effluents The NRC inspector reviewed the licensee's records and reports concerning radwaste systems and effluent releases to determine compliance with the requirements of 10 CFR Part 50.36(a)(2) and Sections 6.9.1.7, 6.14, and 6.15 in the T The NRC inspector reviewed the semiannual reports for the periods July 1 through December 31, 1986, and January 1 through June 30, 198 These reports were written in the format described in NRC Regulatory Guide 1.21 and contained the information required by T No violations or deviations were identifie . Exit Interview The NRC inspector met with the NRC senior inspector and the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on January 22, 1988. The NRC inspector summarized the scope and findings of the inspection and discussed the inspector's observations. The licensee representatives stated at the exit interview that they would evaluate the NRC inspector's observations and concerns and take necessary corrective action to implement program improvements.

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ATTACHMENT 1 Wolf Creek Generating Station NRC Inspection Report: 50-482/88-02 Documents Reviewed Title Revision 'Date Adminsitrative' Procedures ADM-01-008, Site Chemist Duties and Responsibilities 3 06/02/87

.ADM-02-013, Radwaste Coordinator 1 03/11/86 ADM-04-001, Chemistry Group Organization 10 11/17/87 ADM-04-004, Chemistry Technician Training Program 9 11/03/87 ADM-04-006, Preparation of the Monthly "Preliminary 2 03/10/87 Report on Radioactive Releases" and the

"Radioactive Effluent Releases" Portion of the Semiannual Operating Report ADH-04-020, Chemistry Surveillance Program 13 08/18/87 ADM-04-020, Appendix 1, WCGS Technical Specifications (e)

Surveillance Report ADH-04-020, Appendix 2, WCGS Technical Specification (c)

Surveillance Report (Cumulative Doses and ProjectedDoses)

.ADM-04-020, Appendix 4, Table 4.11-2 Surveillance Report (b)

ADM-04-020, Appendix 5, Table 4.11-1 Surveillance Report (b)

ADM-04-023 Radioactive Releases 8 12/08/87 ADM-04-023, Appendix I, Radioactive Liquid Release 8 12/08/87 Permit ADM-04-023, Appendix II, Radioactive Gas Release Permit 8 12/08/87 Chemistry Manual Procedures CHM-01-002, Sampling of the Liquid Release 3 09/02/87 Batch Tanks CHM-01-003, Sampling of the Waste Gas Decay Tanks 2 11/21/85

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, -2-CHM-01-004, Sampling Containment Atmosphere for 6 09/02/87 Radioactive Gases and Tritium .

CHM-01-005, Exchange of Unit and Radwaste Vent -7 09/22/87

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Particulate and Iodine. Filter, Cartridges-CHM-01-006, Sampling of Containment Atmosphere 3 09/02/87 for Particulate and Iodine Concentration r4M-01-007, Sampling of.the Unit and Radwaste Vent 4 07/14/87 For Radioactive Gas and Tritium CHM-01-009, Sampling of the Spent Fuel Building Vent 4 09/28/87 for Radioactive Gases and Tritium

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CHM-03-140, Preparation.of Radioactive Liquid Release 4 04/29/87 Permit CHM-03-145, Documentation of Liquid Batch Releases 3 02/06/87 CHM-03-146, Documentation of Liquid Continuous Release 2 02/06/87

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CHM-03-150, Use of the N06700 LRW/GRW System for 5 04/29/87 Liquid Radioactive Releases CHM-03-151, ND6700 Midrelease Update 1 06/09/87 CHM-03-152, Use of the N06700 LRW/GRW System 8 10/21/87

for Containment Purges

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l CHM-03-153, Use of the ND6700 LRW/GRW System 7 01/07/88 i for Gas Decay Tank Releases

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CHM-03-154, Use of the ND6700 LRW/GRW System 7 05/29/87

for Unit Vent and Radwaste Building Continuous Releases CHM-03-160, Preparation of Waste Gas Release Permit 3 11/25/87 j

l CHM-03-161, Preparation of Radioactive Gas Release 3 10/13/87 l Permit for Containment Purges CHM-03-162, Preparation of Vent Release Permit 2 06/16/87 i

CHM-03-165, Airborne Particulate and Halogen Release 2 02/19/87 Summary l CHH-03-166, Airborne Gaseous Release Summary 2 02/02/87 l

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-3- Surveillance Tests STS-CR-001, Control Room Daily: Logs 6 06/02/87 STS-CH-010, Calibration of Liquid Proces's 0 05/27/86 and Effluent Monitors STS-CH-011,. Calibration of the Particulate Detector- 0 04/29/86 for Gaseous Monitors STS-CH-012,' Calibration of the Iodine Detector 0 04/29/86 for Gaseous Monitors STS-CH-013, Calibration of the Gaseous Detector 0 05/13/86 for. Gaseous Monitors STS-CH-014, Calibration of Monitors GT RE-21A 0 04/29/86 and GT RE-21B STS-IC-250A, Analog Channel Operational Test Containment 4 02/11/86 Atmosphere and RCS Leakage Radiation Monitor GT RE-32 STS-IC-2508, Analog Channel Operational Test Containment 4 02/11/86 Atmosphere and RCS Leakage Radiation Monitor GT RE-31 STS-IC-252A, Analog Channel Operational Test New Fuel 2 10/30/86 Pool Criticality Monitor SD RE-35 STS-IC-2528, Anslog Channel Operational Test _New Fuel 2 10/30/86 Pool Criticality Monitor SD RE-36 STS-IC-253A, Analog Channel Operational Test Fuel Building 3 02/11/86 Exhaust Radiation Monitor GG RE-27 STS-IC-2538, Analog Channel Operational Test Fuel Building 4 08/11/87 Exhaust Radiation Monitor GG RE-28 STS-IC-254A, Analog Channel Operational Test Fuel 4 10/30/86 Pool Bridge Crane Area Criticality Monitor SD RE-37 STS-IC-254B, Analog Channel Operational Test Spent 3 10/30/86 Fuel Pool Area Criticality Monitor 50 RE-38 STS-IC-255A, Analog Channel Operational Test Control Room 4 07/14/87 Air Intake Radiation Monitor GK RE-05 STS-IC-2558, Analog Channel Operational Test Control 4 08/11/87 Room Air Intake Radiation Monitor GK RE-04

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STS-IC-450A,' Channel Calibration RCS Leak Detection 3' 02/11/86 Radiation Monitor GT RE-32-STS-IC-4508, Containment Purge System RCS Leak Detection 3 01/15/86 Radiation Monitor GT'RE-31 STS-IC-452A, Channel Calibration New Fuel Pool 1 05/01/85 Criticality Monitor 50 RE-35 STS-IC-452B, Channel Calibration New Fuel Pool 1 05/01/85 Criticality Monitor SD RE-36 STS-IC-453A, Channel Calibration Fuel Building Exhaust 3 02/25/86 Radiation Monitor GG RE-27 STS-IC-453B, Channel Calibration Fuel Building Exhaust 3 02/11/86 Radiation Monitor GG RE-28 STS-IC-454A, Channel Calibration Fuel Pool Bridge Crane 3 05/02/85 Area Criticality Monitor 50 RE-37 STS-IC-454B, Channel Calibration Spent Fuel Pool 2 05/02/85 Criticality Monitor SD RE-38 STS-IC-455A, Channel Calibration Control Room Air Intake 3- 02/11/86 Radiation Monitor GK RE-05 STS-IC-455B, Channel Calibration Control Room Air Intake 3 02/11/86 Radiation Monitor GK RE-04 STS-IC-456, Channel Calibration Liquid Radwaste System 2 12/13/84 Discharge Radiation Monitor HB RE-18 STS-IC-457, Channel Calibration Steam Generator Blowdown 2 12/15/84 Effluent Radiation Monitor BM RE-52 STS-IC-458, Channel Calibration Turbine Building Effluent 4 07/02/85 Radiation Monitor LE RE-59 STS-IC-459, Channel Calibration Secondary Liquid Waste 2 12/15/84 Radiation Monitor HF RE-45 Quality Assurance Surveillances and Audits 1987 Revised Third and Fourth Quarter Audit and 1 09/04/87 Surveillance Schedule 1988 First and Second Quarter Audit and Surveillance 0 12/23/87 Schedule

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QA Surveillance Report TE:53359 S-1469, Uncontrolled Releases, dated October 8, 1986 l QA Surveillance ~ Report TE:53359 S-1564, Implementation of STS-IC-250B, dated August 24, 1987 QA Surveillance Report TE:53359 S-15/',, Offsite Dose Calculation Manual, dated July 14, 1987

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QA Audit Report TE:50140-K052, Radiation Protection, dated May 28, 1985 QA Audit Report TE:50140-K106, Radioacitve Waste Management and Transportation Activities, dated May 5, 1986 QA Audit Report TE:50140-K148, Surveillance Testing and inspection, dated i February 5, 1987 QA Audit Report TE:50140-K162, Radioactive Waste Management and

Transportation Activities, dated May 6, 1987

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QA Vendor Audit Report TE:58226-K001, Mine Safety Applicances, dated l

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December 10-11, 1985

. Wolf Creek Generating Station Semiannual Ef fluent Release Reports i

July 1 through December 31, 1986 4 January 1 through June 30, 1987 j i

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