IR 05000482/1987012

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/87-12. Understands That Personnel Evaluation Procedures Revised to Ensure That Reg Guide 1.8-1975 Recommendations Met

ML20237J431
Person / Time
Site:	Wolf Creek
Issue date:	08/24/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
RTR-REGGD-01.008, RTR-REGGD-1.008 NUDOCS 8708260163
Download: ML20237J431 (2)

Text

{{#Wiki_filter:' ' ' AUG 2 41987 In Reply Refer To: Docket: STN 50-482/87-12 Wolf Creek Nuclear Operating Corporation

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ATTN: Bart D. Withers President and Chief Executive Officer , P. O. Box 411  : Burlington, Kansas 66839 Gentlemen: Thank you for your letter of July 30, 1987, in response to our letter and Notice of Violation dated June 30, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio Even though your response contains adequate actions to correct the violation, there are statements made in the letter that need to be addressed. In your July 30, 1987, response you stated that Wolf Creek Nuclear Operating Corporation believed that the individual designated as the new Radiation Protection Manager satisfied the qualification criteria in Regulatory Guide 1.8-1975. This matter was discussed during a telephone conversation on August 18, 19d7, between Mr. Gary Boyer of your staff and Messrs. Blaine Murray and Ron Baer of this office. Based on the results of these discussions, it is our understanding that you now have a better understanding regarding the previous work experience that can be included as meeting the qualification criteri It is also our understanding that your persor.nel evaluation procedures have been revised to ensure that Regulatory Guide 1.8-1975 recommendations are me We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, ORIGINAL SIGNED BY: 8708260163 y02 PDR ADOCK PDR J. E. Gagliardo, Chief G Reactor Projects Branch cc: Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P. O. Box 411 Burlington, Kansas 66839 (cc continued next page) f l /-{ RIV:FRPS) C:FRPS'b BMurray~) C:RPSB I C- . C:RPB 4 REBaer/jt LAYand DRf ter 9 /7 0/8 JEGagli{do 59 GI /87 i). /.l[V87 f % /87 }hl/f7

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Wolf Creek Nuclear Operating -2-Corporation

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Gary Boyer, Plant Manager Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 , Mr. Robert D. Elliott, Chief Engineer i

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Kansas Corporation Commission Fourth Floor, Docking State Office Building _ Topeka, Kansas 66612-1571 Kansas Radiation Control Program Director bec to DMB (IE06) bcc distrib. by RIV: RPB Myron Karman, ELD, MNBB (1) Resident Inspector R. D. Martin, RA Section Chief (RPB/B) DRSP RPSB RIV File RSB MIS System RSTS Operator D. Weiss, RM/ALF Inspector Section Chief L. A. Yandell R. L. Bangart R. E. Hall Project Inspector, RPB R. P. Warnick, RIII Resident Inspector, RIII

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P. O' Conner, NRR Project Inspector s O _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - -

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W4,M.F CREEK O' 'oM

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NUCLEAR OPERATING CORPORATION #Jg f g 1 sert o. wnters c7$,"7uw. omc., '.

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July 30, 1987 U.S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D.C. 20555 Letter: WM 87-0205 Re: Docket No. 50-482 ' Ref: Letter dated 6/30/87 from JEGagliardo, NRC, to BDWithers, WCNOC Subj : Response to Violation 482/8712-01 Gentlemen: Attached is a detailed response to violation (482/8712-01) which was documented in the Referenc The violation concerns the qualifications of the Site Health Physicist as they relate to his abilitly to assume the function of the Radiation Protection Manage If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours,

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Bart D. Withers President and

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Chief Executive Officer BDW:11k Attachment cc: P0'Connor (2) RMartin

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JCummins  ;

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O po W Wl4 P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 3644831 (f@ U[ '\

 -w An Equal OpportunWy EnWoyer MfW.,/ VET m

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Attcchm nt to WM 87-0205 Pcge 1 of 2 July 30 , 1987

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Violation (482/8712-01): Radiation Protection Manager Qualifications Finding: Technical Specification 6.3.1 states "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS3.1-1978, 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 states the Radiation Protection Manager should have a Bachelor's~ Degree or the equivalent, including some formal training in Radiation Protection and at least 5 years of professional experience in applied radiation protectio Contrary to the above, the NRC inspectors determined on May 21, 1987, the Site Health Physicist did not meet or exceed the qualifications of Regulatory Guide 1.8, September 197 The Site Health Physicist satisfied - the bachelor's degree equivalent requirements, but only had 3 years of

 . professional experience in applied radiation protectio Reason for Violation:

Wolf Creek- Nuclear Operating Corporation (WCNOC) ' believes that the individual : who held the Site Health Physicist position on May 1, 1987 does meet or exceed the qualifications of Regulatory Guide 1.8, September 197 The professional responsibilities assigned to the individual from May, 1983 to the time of appointment as Site Health Physicist (April, 1987) was reviewed by station management and determined to be directly applicable to the experience requirements of Regulatory Guide The activities included, but were not limited to, such activities as Off-site Dose Calculation Manual (ODCM) development, process monitor calibration procedure development, and Regulatory Guide 1.21 semi-annual report preparatio Even though _the above activities were performed by the individual while assigned to the station chemistry group, the professional experience requirement has been met as the experience base and knowledge gained in applied radiation protection was not lessene Corrective Steps Which Have Been Taken and Results Achieved:

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Even though WCNOC believes the individual met the required qualifications and full compliance to Regulatory.' Guide 1.8 was met, several corrective steps have been taken to alleviate the NRC's concern with this issu The Site Health Physics group has been transferred to the Plant Support Group under the Superintendent of Plant Support who meets the Regulatory Guide 1.8, September 1975 criteria for Radiation Protection Manage The Superintendent of Plant Support has been assigned as the Radiation Protection Manager until the Site Health Physicist gains the additional two years of professional experience in applied radiation protection ~. , .. Additionally, a change to Technical Specifications, Section 6.3.1, has been submitted which changes the requirement that the Site Health Physicist meet the Radiation Protection Manager qualification This change will require that the Radiation Protection Manager meet or exceed the qualifications of Regulatory Guide 1.8, September 197 .__ __

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Att:ch: nt to WM 87-0205- Page 2 of 2

  . July 30,1987
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Corrective Steps Which Will Be Taken To Avoid Further Violations: The Superintendent of Plant Support will continue to hold the position of Radiation Protection . Manager until the -Site Health Physi,cist gains addit 19nal professional experience in applied radiation protectio The Date When Full Compliance Will Be Achieved: Full compliance will be achieved when the NRC formally approves the Technical Specification change to Section 6. =

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