IR 05000482/1988032

Ack Receipt of 890213 & 28 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/88-32

ML20236A180
Person / Time
Site:	Wolf Creek
Issue date:	03/09/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
Shared Package
ML20236A182	List: IR 05000482/1988032 ML20236A184
References
NUDOCS 8903160448
Download: ML20236A180 (2)

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MAR - 91989

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In Reply Refer To:

Docket: STN 50-482/88-32 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 .

Burlington, Kansas 66839 Gentlemen:

Thank you for your. letters of February 13 and 28,1989, in response to our letter and Notice of Violation dated January 12, 1989. We have reviewed your .

replies and find them responsive to the concerns raised in our Notice of Violation. 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 lly A. D. Beach L. J. Callan, Director Division of Reactor Projects cc:

Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P.O. Box 411 Burlington, Kansas 66839 (cc's continued)

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l Wolf Creek Nuclear Operation Corporation -2-l Wolf Creek Nuclear Operatir.g Corporation ATTN: Gary Boyer, Plant Manager P.O. Box 411 i Burlington, Kansas 66839 l Kansas Corporation Commission ATTN: Robert D. Elliott, Chief Engineer Fourth Floor, Docking State Office Building Topeka, Kansas 66612-1571 Kansas Radiation Control Program Director i

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bec distrib, by RIV w/ copy of licensee's letter: 1 R. D. Martin, RA J Myron Karman, ELD,. MNBB (1)

Resident Inspector Section Chief, DRP/A)

DRP j RPB-DRSS -

RIV File DRS MIS System RSTS Operator Lisa Shea, RM/ALF Inspector Section Chief B. Murray  ;

R. L. Bangart i R. E. Hall Project Engineer, DRP/A B.DeFayette, RIII Callaway, RIII ,

D. Pickett, NRR Project Manager l l

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W4)NUCLEAROPERATING LF CREEK g-1 - '

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Bart D. Vesthers President sad

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February 13, 1989 WM 89-0047 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 Washington, D. C. 20555 Reference: Letter dated January 12, 1989 from L. J. Callan, NRC, B. D. Withers, WCNOC Subject: i Docket No. 50-482: Response to Violation 482/8832-01, 02, 03 and 04

Gentlemen:

ttached is Wolf Greek Nuclear Operating Corporation's (WCNOC) response to Violations 482/8832-01, 02, 03 and 04 which were documented in the Referenc Violation 482/8832-01 involved the failure to post notices of violation Violation 482/8832-02 involved the failure to post high radiation areas. Violation 482/8832-03 involved the failure to follow procedures for collection and transfer of radioactive wast Violation 482/8832-04 involved the failure to meet transportation regulation Additionally, the reference requested a response on the steps that WCNOC has taken and plans to take to improve the performance in the areas of inattentiveness of health physics technicians and apparent deterioration in l

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the effectiveness of the health physics supervisory staff. Per discussions on February 7, 1989 between Mr. E. J. Holler, NRC Region IV, and Mr. K. Petersen, WCNOC, a response will be provided to the concerns by March 1, 198 If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours, L

Bart D. Withers President and *

BDW/jad Chief Executive Officer Attachment cc: B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a i

R. D. Martin (NRC), w/a D. V. Picke t t eDRE$ Alv/Burlington, KS 66839 / Phone:(316) 364 8831

. An Equal opportundy Envoyer WFACVET

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Attachrant to WM 89-0047 Page 1 of 7 I Violation (482/8832-01): Failure to Post Notices of Violations Finding:

10 CFR Part 19.11(a) requires that each licensee shall post current copies of certain documents including any Notice of Violation involving ,

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radiological working conditions and any response from the license Contrary to the above, the NRC inspectors determined on November 15, 1988, that the licensee had not posted che' Notice of Violation issued with NRC Inspection Report- 50-482/88-25, dated October 21, 1988, which contained two

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violations involving radiological working conditions and the response to the

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Notice of Violatio Reason for Violation:

Upon receipt of NRC Inspection Report 482/88-25, Licensing and Plant Support personne1' reviewed the Notice of Violation and determined that the two violations did not specifically involve radiological working conditions and

'therefore did not require posting- in accordance with 10 CFR Part 19.1 Discussions with the NRC inspectors revealed that their interpretation of 10 CFR 19.11(a)(4) is that this posting requirement applies to any 10 CFR Part 19.12 or Part 20 violation, or any violation of radiation protection program implementing procedure WCNOC disagrees with this very conservative interpretation of the requirements and believes that this interpretation may result in the posting of violations that do not involve radiological working condition However, using the NRC inspectors'

interpretation, WCNOC agrees that the violations issued with NRC Inspection Report 482/88-25 should have been poste Corrective Steps That Have Been Taken and Results Achieved:

After discussions with the NRC inspectors regarding their interpretation of the posting required by 10 CFR 19.11(a)(4), WCNOC posted copies of the Notice of Violation in the designated location Procedure ADM 01-085, "10 CFR Posting Requirement" and KP-L2201, "NRC Correspondence Processing" were reviewed against the 10 CFR 19 posting requirements and have been revised to reflect the above' NRC inspectors'

interpretation Corrective Steps Which Will Be Taken to Avoid Further Violations:

The above corrective steps should prevent further violation j Date When Full Compliance Will Be Achieved _:

Full compliance has been achieve )

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Attachment to WM 89-0047

Page 2 of 7 Violation (482/8832-02): Failure to Post High Radiation Areas Findinz:

Technical Specification (TS) 6.12.1 requires, in part, that high radiation areas, gasam exposure rates greater than or equal to 100 milliram per hour (mrem /hr) but less than 1000 mrem /hr at 18 inches, be conspicuously posted in accordance with 10 CFR Part 20.20 Contrary to the above, NRC inspectors determined on November 15, 1988, that two accessible areas within containment exhibited radiation levels of 100 l mrem /hr and 160 mrem /hr at 18 inches were not properly poste Reason for Violation:

The root cause for the failure to properly post a High Radiation Area has been attributed to non-licensed utility personnel erro Extensive review of all surveys performed in the Reactor Coolant Drain Tank (RCDT) area on the 2000' elevation indicated that hot spots were detected at various times prior to November 15, 198 Based on the surveys, the radiation levels would change from a High Radiation level to less than 100 mrem /hr depending on the evolutions associated with the RCD On at least three of the surveys, prior to November 15, 1988, one of the hot spots was recorded as 1 100 mrem /hr at 18 inches. These surveys did not indicate that the area was posted as a High Radiation Area. However, two HP Supervisors, when questioned, remembered the area being posted as " Caution High Radiation Are RWP Required for Entry" during their Containment entries prior to November 15, 198 Sometime during this time period (October 7 to November 15, 1988), l scaffolding was installed in the area near the RCDT. Evidently, the posting  !

was removed during the scaffolding installation and/or as a result of ,

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radiation levels decreasing below 100 mrem /hr and the area was not repeste Personnel error was involved in that the area was not reposted for radiation levels above 100 mrem /hr at 18 inches, as a High Radiation Area.

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I Corrective Steps That Have Been Taken and Results Achieved Technicians surveyed the areas and erected a barrier and posted the two areas immediately after being informed of the NRC Inspector's findings on November 15, 198 Technicians were made aware of the finding and were reminded to ensure that all areas were posted properl Subsequent surveys show that the area was posted properly as a High Radiation Area.

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Attachment to WM 89-0047

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Page 3 of 7 Corrective Steos Which Will Be Taken to Avoid Further Violations:

A memo was sent to all HP personnel describing thememo, In the violation and the HP personnel apparent circumstances that caused the violatio are directed to 03-013 ensure that all areas are posted in accordance the with location of procedure HPH and to note on survey documentation, such postin They are also cautioned to be especially sensitive to areas as the RCDT, which may experience radiation level changes on a daily basi to place in the contractor A copy of the memo has been sent to Training Training Files and in the Impact Files for HP Technician Trainin Date When Full Compliance Will Be Achieved:

Full compliance has been achieve Violation (482/8832-03): Failure to Follow Procedures FindinR:

" Procedures for personnel Technical Specification 6.11 requires that, requirements of radiation protection shall be prepared consistent with theand adhered to for all 10 CFR Part 20 and shall be approved, maintained,

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operations involving personnel radiation exposures.'

Health Physics Procedure HPH 09-503 " Collection and Transfer of Radioactive Waste,' Item 5.1.3.4.1, requires that each container or bag of radioactive waste must be narked, when not in the presence of Health Physics personnel, whichever with the highest contact radiation level or the background level, is appropriat . 16, 1988, that Contrary to the above, NRC Inspectors determined on Novemberthe prestenciled approximately ' six bags of radioactive material (with Radioactive Material,") and three capped and unmarked yellow containing other bags of radioactive material, located in an outside inscription, drums area adjacent to the radwaste and containment buildings, were not adequately controlled and had not been properly marked to indicate the radiation

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level Reason for Violation:

The root cause for improper bagging of waste materials has been attributed to non-licensed personnel erro .

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Attachment to WM 89-0047

• Page 4 of 7 had been used in the I The filters had no l tio externall l The material in question consisted levels measurable of filters thatseconda trash, a sample had detectable However, to contamination or radiation allow free-release of the materials as cleandioactive was present material which to be collected and analyzed to ensure no rathe materials Sincewere the placed in yellow bags internally. Consequently, L'

d in Step 2.3 of HPH are prestenciled with ' CAUTION was the material RADIOACTIVE was adequately MATER the contract technicians felt that d 09-503),

controlled and did not present a radiological hazar . i s of procedure error was involved in that the specific instruct ont ining the filters Personnel HPH 09-503 were not followed, which required the bags con abackground to be marked indicating radiation levels asas non-detectable Achieved:

Corrective Steos That Have Been Taken accordance andwithResults procedure all bags of j

that The bags were resurveyed and properly marked reminded in ith procedure HPH 09-503, HPH 09-50 Technicians and deconners were l radioactive material must be marked in accordance wpersonne l when not in the presence of Health Physica h Violations:

g Corrective Steos Which Will Be Taken to Avoid Furt er been revised to add a NOTE which emphasizes the Procedure HPH 09-503 has bag must be marked i peresent the fact that any yellow " Radioactive Material" irrespective of the lev procedure, on the material in the ba Date When Full Compliance Vill Be Achieved _:

Full compliance has been achieve Failure to Meet Transportation Regulations _

Violation (482/8832-04):

Finding: shall transport any licensed 10 CFR 71.5(a) requires that no licensee l ce of use. or deliver material outside the confinescarrier of his plant or for transport, other pappropriate a unless the licensee to the l

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any licensed material to a i

complies with applicable requirements18 of the regulat ons '

I mode of transport of DOT in 49 CFR Parts 170-l i

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. Attachment to WM 89-0047

• Page 5 of 7 1 49 CFR 173.425(c)(3) requires that for shipments of low specific activity material in exclusive use vehicles the external radiation levels comply with 49 CFR 173.44 CFR 173.441(b)(2) requires that radiation levels not exceed 200 including mrem the top /hr and on any point on the outer surfaces of the vehicle, underside of^the vehicl CFR Parts 173.425(b)(6) and 49 CFR 173.448(a) require that a shipment be braced so as to prevent shifting of lading, radioactive material containers,  !

under conditions norma 11y' incident to transportatio I j

contrary to the above, radiation surveys of by state of Nevada inspectors at licensee Waste Shipment 88B08 I

1988, Beatty, Nevada, on June 3, determined that the radiation level at one point under the transport trailer was 260 to 275 mrem /hr, and that the lading (55 gallon drums / barrels) had shifted during transpor I Reason for Violation:

The root cause for exceeding radiation limits for transportation and for inadequate bracing has been attributed to inadequate, procedure l The instrument normally used at Wolf Creek Generating StationThe (WCGS) for radiation j monitoring radiation levels is the R0-2 or R0-2A lon chambe level measured by the Nevada inspector was in an isolated area near the The !

trailer axle that was difficultinstrument to access with an R0-2 instrumen with a small Geiger Hueller Nevada inspector used an E-520 and which detector, wh'ich made access to the point in question much easier, than the ,

also indicated a significantly (about 30%) higher radiation level i ion chamber used at WCG Personnel from WCGS traveled to the Nevada site  !

to check the shipment' prior to it being unloaded. The spot measured by the Nevada inspector as 260 to 275 mrem /hr with the G-M probe, was measured with'

by a WCGS. R0-2 and some difficulty, at approximately the same locationSince the highest reading indicated a maximum reading of 200 mrem /h !

listed on the manifest was about 170 mrem /hr, either the 200 mrem /hr spot or was not detected by the technician using the R0-2 when surveyed at WCGS, of the the slight shifting of the load during transit changed the location radiation readin l l

The shifting of lading is thought to be due to allowing too much space Shipment 88B08 shifted forward between the drums when they were loade shif It indicating that horizontal space was available for the load to '

appears that the ' riding up onto the locking rings of adjacent * containers,"

was also a result of the excess space available for the drums to move horizontally and ride up onto other drum _ _ _ _ - - _ _ _ _ _ _ _ _

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. Attachment to WM 89-0047 i

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Procedure HPH 09-513, ' Outgoing Vehicle Surveys' was inadequate in that it had no instructions for the technician to use different or additional survey instruments when radiation levels were near the limits and/or when areas were difficult to access with the R0-2 ion chambe Procedure HPH 09-514, " Transport Vehicle Loading and Inspection' was inadequate in that it did not require the loader and the QC Inspector to ensure that the drums were packed tightly together prior to installing the rear bracing. According to the Barnwell, S.C. Burial Site, they have had no problems with shipments of drums shifting, when the drums are packed closely together and properly braced and shored at the rea Corrective Stens That Have Been Taken and Results Achieved:

Procedure HPH 09-513 was revised to include a note that instructs the technicians to use both an R0-2 ion chambay and an E-520 GM type instrument to measure radiation levels external to the vehicle (trailer) for Nevada shipments when packages (drums) of greater than 500 mrem /hr are included in the shipmen Some shipments of drums were made in which the drums were banded together to help prevent shiftin The type of trailer required for banded drums is no longer availabl WCGS personnel have researched information en adequate bracing by contacting other utilitics and other burial site One shipment of drums was made to the Barnwell, site in Decembe The drums were packed closely together and braced and shored at the rear. They were braced at the top in the rear with a friction ba They were shored at the bottom in the rear with toe-nailed two-by-four There were no problems with lading shift or radiation levels at the burial

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sit Corrective Stens Which Will Be Teken to Avoid Further Violations:

Procedure HPH 09-513 has been further revised to require radiation surveys external to the vehicle (trailer) on all shipments, irrespective of burial site destination, to be surveyed by both an E-520 GM type instrument and an R0-2 ion chamber when packages or drums of greater than 500 mrem /hr are included in the shipmen .

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. Attachment to WM 89-0047

. Page 7 of 7 An engineering evaluation has been conducted to determine if additional bracing requirements are necessary for radwaste shipment The disposition has been reviewed and has been factored into procedure HPH 09-514, as appropriat Procedure HPH 09-514 was revised to require all shipments of drums to be tightly packed from front to rear before bracing and shoring are properly placed at the rear. Additional guidance was incorporated into the procedure to prevent movement of the drums in the vertical directio Date When Full Compliance Will Be Achieved:

Full compliance has been achieve .

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