ML20235E869

Insp Rept 50-482/87-17 on 870817-21.Violations Noted. Major Areas Inspected:Radiation Protection Program Including Organization & Mgt Controls,Training & Qualifications & ALARA Program

ML20235E869
Person / Time
Site:	Wolf Creek
Issue date:	09/21/1987
From:	Baer R, Murray B, Scott H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235E760	List: ML20235E757 ML20235E782 ML20235E869
References
50-482-87-17, IEB-79-20, NUDOCS 8709280301
Download: ML20235E869 (7)

See also: IR 05000482/1987017

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= APPENDIX B

L , U.S. NUCLEAR REGULATORY COMMISSION

L REGION-IV

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I- NRC Inspection Report: 50-482/87-17 License: NPF-42

Docket: 50-482

Licensee: . Wolf Creek Nuclear Operations Corporation (WCN00)

P. O. Box 411

Burlington, Kansas 66839

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Facility Name: Wolf Creek Generating' Station (WC35)

~ Inspection At: WCGS site, Burlington, Kansas

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Inspection Conducted: August 17-21, 1987-

Inspectors: [# T/O/[7

R. E. Baer, Madiation Specialist, Facilities Date

Radiological Protection Section

W&1W Y

I[ L. Scott (/ Radiation Specialist, facilities Date

W/7N7

Radiological Protection Section

Approved: () k)Mff

5711Grray, Chicif, Facil %ies Radiological

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Protection Section /

Inspection Summary

Inspection Conducted August 17-21, 1987 (Report 50-482/87-17)

Areas Inspected: Rectine, unannounced inspection of the radiation protection

program including organization and management controls, training and

qualifications, and the ALARA program.

Results: Within the areas inspected, two violations (failure to provide

retraining, paragraph 7; and failure to maintain training records, paragraph 8)

were identified.

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DETAILS

1. Persons Contacted

WCNOC

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• G. D. Boyer, Plant' Manager

• H. M. Davis, Health Physics (HP) Supervisor

• T. F. Deddens Jr. , Manager, Outage

• A. A. Freitag, Manager, Nuclear Plant Engineering

• E. C. Holman, HP Supervisor

J. M. Isom, HP Technician

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

• W. M. Lindsay, Supervisor, Quality Systems

'*0. L. Maynard, Manager, Licensing

G. A. McClelland, Quality Assurance (QA) Auditor

• J. F. McMahon, Supervisor, Technical Training

• C. M. Medenciy, Supervisor, Radioactive Waste

T. S. Morrill, Site Health Physicist

T. G. Moreau, Radiation Protection Training Instructor-

• W. L. Mutz, Manager, Nuclear Plant Engineering Services

• M. M. Nichols, Superintendent, Plant Support

• D. K. Parks, Training Program Coordinator, General Employee / Radiation

Protection Training

• G. J. Pendergrass, Licensing Engineer

• W. J. Rudolph II, Manager, QA

• C. L. Taylor, HP ALARA Coordinator

• M. G. Williams, Superintendent, Regulatory, Quality and Administration

• J. A. Zell, Manager, Nuclear Training

NRC

• B. L. Bartlett, Resident Inspector

J. E. Cummins, Senior Resident Inspector

• Denotes those individuals present during the exit interview conducted on

August 21, 1987.

The NRC inspectors also interviewed several other licensee employees

including administrative, HP, and chemistry personnel.

2. Inspector Observations

The following are observations the NRC inspectors discussed with the

licensee during the exit interview on August 21, 1987. These observations ,

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

observations were identified for licensee consideration for program

improvement, but the observations have no specific regulatory requirement.

The licensee stated that the observations would be reviewed.

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e a.: I QA Auditor Trainin'a.

QA auditors conducting'au'dits of HP activities have not received.

HP technical training in the areas:they are responsible,for auditing.

b. QA Technical Reference File

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'Apnlicable HP. technical reference material'is not maintained by QA.

atdit personnel responsible for auditi.ng HP activities,

c. Dos'imetry Clerk Training

Afformal; training program has not been' established for dosimetry

clerks responsible for issuance of thermoluminescent dosimeters (TLD)

and performing whole body counts.

.d . Dosimetry Records Quality Control Program

'A quality control program has not been established,for dosimetry data

" being entered into the dosimetry computer records system,

e. Preventative Maintenance Request (PMR) ALARA Review

The ALARA group.had not received the PMR work packages for the

' October 1987 refueling outage in order to allow adequate time.for

proper ALARA reviews.

f. Mockup' Training

0- Training department radiation protection instructors. had not been

considt. red for attendance in.the steam generator jumper training

n Course,

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g. Training of Instructors

Training department instructors responsible for conducting radiation

protection training had not received HP technical training in order

to maintain proficiency in their assigned discipline.

3. Open Items

The NRC inspector discussed the following open item with the licensee

during the exit interview on August 21, 1987. Open items are matters that

require. turther review and. evaluation by the NRC inspector or licensee.

Open: items are used to docimient, track, and ensure adequate followup on

matters of concern to the NRC inspector.

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.(0 pen) Open Item (482/8717 03): Health Physics Staff Trai..ing - The NRC

inspectors-determined that there is no formal, organized training program

for health physics supervisors and professionals that addresses goals,

objectives, and training frequency. This is consider (d an gpen item

pending. licensee action (482/8717-03)

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4. P_regram 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

83522 Organization and Management Controls (Radiation Protection)

02.01 - Organization, Responsibilities, and Authorities

02.02 - Staffing

02.03 - Identification and Correction of Weaknesses

02.04 - Audits and Appraisals

02.05 - Communication to Employees

02.06 - Documentation and Implementation

83722 Organization and Management Controls (Radiation Protection)

02.01 - Organization

02.02 - Staffing

02.03 - Radiation Protection Manager

02.04 - Identification and Correction of Program Weaknesses

02.05 - Audits and Appraisals

83523 Training and Qualifications (Radiation Protection)

02.01 - Training and Qualification Program - 0 (see

paragraph 3)

02.02 - Education and Experience

02.03 - Adequacy and Quality of Training - V (see

paragraph 8)

83723 Training And Qualifications (Radiation Protection)

02.01 - Adequacy of Training

02.02 - Employee Knowledge

02.03 - Transportation /Radwaste Training - V (see

paragraph 7)

02.04 - Qualification Requirements

02.05 - New Employees

02.06 INP0 Accreditation

02.07 - Audits and Appraisais

02.C3 - Training not Covered by INP0

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83528 ALARA

02.01 - Managcment Policy

02.02 - Assignment of Responsibilities and Authorities

02.03 - Procedures and Standards

02.04 - Indoctrination and Instruction

02.05 - Reviews of Design and Equipment Selection

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83728 -ALARA-

02.01 - Audits and Appraisals

02.02 - Program Changes

02.03 - Worker Awareness and Involvement

02.04 - Goals and Objectives

02.05 -Results and Effectiveness

5. Occupational Ext'sure Expenditures

Table 1 (attached) shows the licensee's person-rem expended versus the

national average for pressurized water reactors for 1984-1986.

Table 2 (attached) identifies the jobs that involved more than 5 person-rem

for the period June 1986 through July 1987.

6. . Disposal of Sewage Sludge

The NRC inspectors reviewed the licensee's procedures for the removal of

sewage sludge from the ensite waste treatment plant. The NRC inspectors

determined that the licensee transfers the sewage sludge to a holding tank

truck where a gamma isotope analysis is performed of a representative

sample prior to offsite disposal.

7. Radioactive Waste Supervisor Retraining

The NRC inspectors reviewed the training and retrainir.g of the individual

recently assigned to the position of HP Ry;ioactive Waste Supervisor.

Inspection and Enforcement Bulletin (IEB) No. 79-20 requires that licensees

who generate low-level waste for burial provide training and periodic

retraining in the DOT and NRC regulatory requirements, the waste burial

license requirements, and licensee instructions and operating procedures

for all personnel involved in the transfer, packaging, and transport of

radioactive material. The licensee is also required to maintain a record

of training dates, attendees, and subject material for future inspections

by NRC personnel.

The NRC inspectors reviewed the training / retraining records of the HP

Radioactive Waste Supervisor. The NRC inspectors determined the individual

had not received the periodic retraining specified in IEB No. 79-20 in that

the previous retraining was last conducted in March 1984.

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l The failure to provide periodic, retraining ~is considered an apparent

i violation ' foIEB No. ' 79-20 (482/8717-01).

8. Training Records

, The NRC inspectors,rev.iewed-training records of licensee employees'. H

Technical Specification 6.10.2 states, in part, that records'of. training

? .and qualification for current members of the unit staff.shall be' retrained .

f for the duration of the unit operating license.

The NRC inspectors reviewed the training department' training records.for

'10 current licensee radiation protection' staff. employees. The-NRC:

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u inspectors-determined that records for two. employees were not complete.

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-The ALARA coordinator records did not include a vendor ALARA training

program' completed in September 1986, and the HP Radioactive Waste

~ Supervisor training records did not include any training completed prior to

. January'1986.-

The failure to maintain: complete training records-for current staff is

considered an apparent.. violation of Technical Specification 6.10.2

<(482/8717-02). .

9. Exit Interview-

lThe NRC' inspectors met with the personnel identified in paragraph 1 at the

conclusion of the inspection ~on August 22, 1987. The NRC inspectors i

summarized the scope.and findings of the inspection.

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ATTACHMENT NO. 1

Table 1

' Person-Rem Expended

Year. 1984 1985' 1986 -1987

'PWR Average 552.0. 416.0 392.0 Not Available

Wolf Creek Under Construction 7.2 142.0 6.0 (1/1 -

8/19/87)

. Table 2

Jobs That Exceeded 5 Person-Rem For 1986-87

Job Description Person-Rem

a. Health Physics Containment Access at Shutdown 17.110

b. Reactor Vessel Head Removal / Replacement 14.406

c. General Access to Non-Specific RWP Areas of the RCA 9.232

d. Routine Access / Maintenance Inside Containment at Shutdown 6.199

e. Testing of Mechanical Snubbers 5.320

f. Removal and Reinsta11ation of Reactor Head Components 5.311

g. Repack Isolation Valves 5.138

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