IR 05000482/1988032
| 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: |
| References | |
| NUDOCS 8903160448 | |
| Download: ML20236A180 (2) | |
Text
____
_-_
l l
,
..
,
MAR - 91989
'
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 maintained.
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)
1 RI RPS:RPB FRPS:RPB C:SEPS:R C:RPB C:RPS/D
- D P g BMur Holler
$Nn DChaney/ sir LRicketson'
'RBaer 4]/, ray 0;/]/89 3/fr/89 J/gp/89
/89 3/7/89
} /i /89 s903160448 800309 ADOCK 0500
gDR
-
_ _ _ _ _ _ _ _
. _ _ _ _ - _ _ _ _ _ _
_ _ _ _ _ - _ _
_
_
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__ -______-_________
-
o
,
?
'
.
.
\\
.
,
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
bec to DMB (IE06)
l bec distrib, by RIV w/ copy of licensee's letter:
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
!
l
!
j
_ _ _ _ _ _
'3 ',.
g e.*
e
.
0I([n/l.L ',
.
.
.
W4)NUCLEAROPERATING C g-1 LF CREEK
>
-
'
.
Bart D. Vesthers
~
President sad
" ' ' " "
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 i
Subject:
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 Reference.
Violation 482/8832-01 involved the failure to post notices of violations.
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 waste.
Violation 482/8832-04 involved the failure to meet transportation regulations.
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 the effectiveness of the health physics supervisory staff.
Per discussions l
'
on February 7, 1989 between Mr. E. J. Holler, NRC Region IV, and Mr.
K.
R.
Petersen, WCNOC, a response will be provided to the concerns by March 1, 1989.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours, L
Bart D. Withers President and
Chief Executive Officer BDW/jad 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
___
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ -
_
__
___-
- - - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
g.-
-
'
Attachrant to WM 89-0047 Page 1 of 7 l.
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
,
'
radiological working conditions and any response from the licensee.
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 violations involving radiological working conditions and the response to the
,
'
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 19.11.
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 procedures.
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 conditions.
However, using the NRC inspectors'
interpretation, WCNOC agrees that the violations issued with NRC Inspection Report 482/88-25 should have been posted.
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 locations.
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'
interpretations.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
The above corrective steps should prevent further violations.
j Date When Full Compliance Will Be Achieved _:
Full compliance has been achieved.
i
_
__ _
_ - - -_
-
.
.
A
- _ - _ _ _
-
__
_ _ - _ _ _ _ - _ _ _ _ _
_
'.
'
,.
.
,
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 20.203.
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 posted.
Reason for Violation:
for the failure to properly post a High Radiation Area has The root cause been attributed to non-licensed utility personnel error.
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, 1988.
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 RCDT.
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 Area.
RWP Required for Entry" during their Containment entries prior to November 15, 1988.
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
,
'
radiation levels decreasing below 100 mrem /hr and the area was not repested.
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.
f l
Corrective Steps That Have Been Taken and Results Achieved I
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, 1988.
Technicians were made aware of the finding and were reminded to ensure that all areas were posted properly.
Subsequent surveys show that the area was posted properly as a High Radiation Area.
l l
l l
___ _ _ _ ___________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- - - - _ _ - - _
_ _ _ _
-
t
.
.
.
,
Attachment to WM 89-0047
Page 3 of 7
'
Corrective Steos Which Will Be Taken to Avoid Further Violations:
A memo was sent to all HP personnel describing the violation and the In the memo, HP personnel apparent circumstances that caused the violation.
ensure that all areas are posted in accordance with are directed to the location of 03-013 and to note on survey documentation, HPH such procedure They are also cautioned to be especially sensitive to areas which may experience radiation level changes on a daily basis.
posting.
as the RCDT, 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 Training.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/8832-03): Failure to Follow Procedures FindinR:
Technical Specification 6.11 requires that,
" Procedures for personnel requirements of radiation protection shall be prepared consistent with theand adhered to for all CFR Part 20 and shall be approved, maintained, 10operations involving personnel radiation exposures.'
,
Health Physics Procedure HPH 09-503 " Collection and Transfer of Radioactive requires that each container or bag of radioactive Waste,'
Item 5.1.3.4.1,when not in the presence of Health Physics personnel, waste must be narked, whichever with the highest contact radiation level or the background level, is appropriate.
16, 1988, that Contrary to the above, NRC Inspectors determined on Novemberthe prestenciled
.
six bags of radioactive material (with approximately ' Radioactive Material,") and three capped and unmarked yellow inscription, located in an outside containing other bags of radioactive material, area adjacent to the radwaste and containment buildings, were not adequately drums controlled and had not been properly marked to indicate the radiation levels.
'
Reason for Violation:
been attributed The root cause for improper bagging of waste materials has to non-licensed personnel error.
.
- - -. - -. -. _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
-___
_ - _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _, _ _ _ _ _.
_ ____ __
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
!
h
.
,
to WM 89-0047 Attachment
Page 4 of 7
had been used in the The material in question consisted of filters thatsecond The filters had no l
l tion.
detectable contamination or radiation levels measurable externally.
trash, a sample had However, to allow free-release of the materials as cleandioactive material was present which to be collected and analyzed to ensure no rathe materials were placed in yellow bags Since the internally. Consequently, L'
are prestenciled with ' CAUTION RADIOACTIVE MATER d in Step 2.3 of HPH adequately the material was the contract technicians felt that was d
controlled and did not present a radiological hazar.09-503),
i s of procedure error was involved in that the specific instruct ont ining the filters HPH 09-503 were not followed, which required the bags con abackground Personnel to be marked indicating radiation levels asas non-detectable Achieved:
Corrective Steos That Have Been Taken and Results j
accordance with procedure The bags were resurveyed and properly marked in all bags of that reminded ith procedure HPH 09-503, l
HPH 09-503.
Technicians and deconners were radioactive material must be marked in accordance wpersonnel.
l when not in the presence of Health Physica h
Violations:
Corrective Steos Which Will Be Taken to Avoid Furt er been revised to add a NOTE which emphasizes the bag must be marked per the g
Procedure HPH 09-503 has fact that any yellow " Radioactive Material" irrespective of the lev i
esent procedure, on the material in the bag.
Date When Full Compliance Vill Be Achieved _:
Full compliance has been achieved.
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 confines of his plant or other p a unless the licensee l
carrier for transport, the i
appropriate to
'
licensed material to a complies with applicable requirements of the regulat ons any 189.
I mode of transport of DOT in 49 CFR Parts 170-
'
l
- _ - _ - _ - _ _
_ _ _______
- - -
._
_
- - - -. - - - - - -
- - -. -
- - - - - - - -
-
'
,.
'
.
.
Attachment to WM 89-0047
.
Page 5 of 7
- requires that for shipments of low specific activity 49 CFR 173.425(c)(3)
material in exclusive use vehicles the external radiation levels comply with 49 CFR 173.441.
173.441(b)(2) requires that radiation levels not exceed 200 mrem /hr 49 CFR including the top and on any point on the outer surfaces of the vehicle, underside of^the vehicle.
173.425(b)(6) and 49 CFR 173.448(a) require that a shipment be 49 CFR Parts braced so as to prevent shifting of lading, radioactive material containers,
!
under conditions norma 11y' incident to transportation.
I j
radiation surveys by state of Nevada inspectors at I
contrary to the above, Beatty, Nevada, on June 3, 1988, of licensee Waste Shipment 88B08 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 transport.
I Reason for Violation:
exceeding radiation limits for transportation and for The root cause for inadequate bracing has been attributed to inadequate, procedures.
The instrument normally used at Wolf Creek Generating Station (WCGS) for l
The radiation j
monitoring radiation levels is the R0-2 or R0-2A lon chamber.
an isolated area near the level measured by the Nevada inspector was in The
!
difficult to access with an R0-2 instrument.
trailer axle that was instrument 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 Personnel from WCGS traveled to the Nevada site
!
ion chamber used at WCGS.
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 /hr.
listed on the manifest was about 170 mrem /hr, either the 200 mrem /hr spot
!
was not detected by the technician using the R0-2 when surveyed at WCGS, or of the the slight shifting of the load during transit changed the location radiation reading.
l The shifting of lading is thought to be due to allowing too much space l
the drums when they were loaded.
Shipment 88B08 shifted forward between shift.
It indicating that horizontal space was available for the load to
'
that the ' riding up onto the locking rings of adjacent * containers,"
appears was also a result of the excess space available for the drums to move horizontally and ride up onto other drums.
- - - - - - - - - _ _ _ _ - -
_ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _. - _ _ _ _ _ _ _ _ _
'
I '.
.'
Attachment to WM 89-0047
.
Page 6 of 7 i
.
l 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 chamber.
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 rear.
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 shipment.
Some shipments of drums were made in which the drums were banded together to help prevent shifting.
The type of trailer required for banded drums is no longer available.
WCGS personnel have researched information en adequate bracing by contacting other utilitics and other burial sites.
One shipment of drums was made to the Barnwell, S.C.
site in December.
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 bar.
They were shored at the bottom in the rear with toe-nailed two-by-fours.
There were no problems with lading shift or radiation levels at the burial
'
site.
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 shipment.
.
_- _ ___ ____ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _
. - _ _ _ _ _ _ _
' :
.
.
.
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 shipments.
The disposition has been reviewed and has been factored into procedure HPH 09-514, as appropriate.
revised to require all shipments of drums to be Procedure HPH 09-514 was 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 direction.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
.
- - - - _ - - - _ _ - - _ _ _. _ _ _.