IR 05000482/1997011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-11

ML20211H084
Person / Time
Site:	Wolf Creek
Issue date:	10/01/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-97-11, NUDOCS 9710060189
Download: ML20211H084 (4)

Text

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OCT - l 1997 Otto L Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 SUBJECT: NRC INSPECTION REPORT 50-482/9711 AND NOTICE OF VIOLATION

Dear Mr. Maynard:

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Thank you for your letter of September 19,1997, in response to our letter and Notice of Violation dated August 21,1997. We have reviewed your reply and find it 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.

Sincor l

Thomas P. Gwyn , Dir ctor i Division of React l r P jects Docket No.: 50-482

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License No.: NPF-42 - '

cc: '

Chief Operating Officer Wolf Creek Nuclear Operating Corp.

P.O. Box 411 Burlington, Kansas 66839 Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 ~

9710060189 971001 \f.hllhkh

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W'olf Creek Nuclear -2-

. Operating Corporation

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Supervisor Licensing--

1 Wolf Creek Nuclear Operating Corp.-

P.O. Box 411 -

' Burlington, Kansas 66839 Chief Engineer Utilities Division Kansas Corporation Commission ,

1500 SW Arrowhead Rd.

Topeka, Kansas.: 66604-4027; Office of the Governor" State of Kansas-

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-Topeka,- Kansas 66612~.

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Attorney General Judicial Center--

301 S.W.10th

!2nd Floor;

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= Topeka, Kansas 66612-1597

- County Clerk

- Coffey. County Courthouse

Burlington, Kansas 66839 1798

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Vick L Coope',r Chief Radiation Control Program l Kansas Department of Health

. and Environment Bureau of Air and Radiation--

Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa

. Division of Emergency Preparedness

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--2800 SW Topeka Blvd -

Topeka, Kansas 66611-1287

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Wolf Creek Nuclear -3-Operating Corporation- OCT - l 1997

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- Regional Administrator Resident inspector -

DRP Director  : SRI (Callaway, RIV)

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Branch Chief (DRP/B) DRS-PSB '

Project Engineer (DRP/B)- MIS System

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Branch Chief (DRP/TSS) RIV File

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' DOCUMENT NAME: R:\_WC\WC711 AK.JFR

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'_ Operating Corporation OCT - l 1997

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DOCUMENT NAME: R:\_WC\WC711 AK.JFR To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/B C:DRP/B , D:DRP jf

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Clay C. Warren WeLF CREEK %w""

' NUCLEAR OPERATING CORPORATION REGiONiv

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I Chief Operating Offcer l

September 19, 1997 WO 97-0099

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! U. S. Nuclear Regulatory Commission i ATTN: Document Control Desk l Mail Station F1-137 j Washington, D. C. 20555 Keference: Letter dated August 21, 1997, from T. P. Gwynn, NRC, to 0. L. Maynard, WCNOC Subject: Docket No. 50-482: Response to Notice of i Violations 50-482/9711-06 and 9711-07 l

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Gentlemen:

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This letter t ra:.=mit s Wolf Creek Nuclear Operating Corporation's (WCNM)

4 response to Notice of Violations 50-482/9711-06 and 9711-07. Violation 9711-

! 06 cites two examples of workers failing to have the correct dosimetry t

required by the Radiation Work Permit. Violation 9711-07 addresses a failure

} to assess and report a loss of emergency communications capability within the

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1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit.

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WCNOC's response to these violations is provided in the attachment. If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4485, or Mr. Richard D. Flannigan at extension 4500.

i l Very truly yours,

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i i_ Clay C. Warren j CCW/jad

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Attachment cc: W. D. Johnson (NRC), w/a

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E. W. Merschoff (NRC), w/a i J. F. Ringwald (NRC), w/a

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J. C. Stone (NRC), w/a i

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Attachmsnt ~ to WO 97-0099 f

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l: viol'ation 50-482/9711-06: ' -

" Technical Specification 6.1.1 requires, in part, that radiation workers-adhere to procedures for personnel radiation protection consistent with

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- ;the requirements.of 10 CFR Part 20 l- Administrative Procedure AP 25B-100, " Radiation Worker Guidelines "

Revision 4, Section 6.3.6,1 states that " Individuals shall comply with .

the-RWP (Radiation Work Permit)-requirement."

icontrary to.the above ~-

l 1..On June 26, 1997,' a worker entered the radiologically controlled area :

i without -the neltron dosimetry required by Radiation Work Permit 970103. ,

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! 2. On July 7, 1997, a worker entered the radiologically controlled area

!> . without the electronic dosimetry required by Radiation Work Permit  ;

970003." "

Reason for Violation l Example Onet l

l On June 26, 1997, a technician, assigned to perform work in the_ Containment Building, attended the Containment entry pre-job briefing. During this briefing, dosimetry requirements :for Containment entry on Radiation tWork Permit (RWP) 970103 were discussed. This discussion ine]uded - the use. of

~ neutron dosimetry- in place _of the normal- thermoluminescent dosimeter x (TLD) .

I During the-briefing the workers were given neutron dose-calculation sheets to

, document appropriate information. -These sheets are ' also used to ~ document I

authorization of the workers to the RWP's . _ After the pre-j ob briefing - _was  :

completed, the Health Physics Technicians covering the activity 'gave the workers authorization'for access on the respective RWPs. This required data input;through the MAPPER computer, which in -turn' updates the - ARACS - computer j used by-the workers for signing.into the RCA. .The time-it takes the MAPPER

, computer. to update the ARACS computer can be lengthy. Also, when-signing in i with a. neutron TLD, a-worker must use the normal TLD, which has the necessary bar-code required for signing in through ARACS,.and then return the normal TLD .

l. to'the storage rack and take.the neutron TLD from the storage rack in the back l of the-Health Physics Shift Technician Office.

The -technician ARACS ' sign

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attempted. this in process three times l . unsuccessfully.. After a short break; on the l fourth attempt, the technician succeeded in the' sign in process. :Throughout this. process the technician was

' distracted by coworkers who_were having the same problem with signing in, and who'had become frustrated .with' the process. The -technician then forgot to i

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change the normal TLD for the required neutron TLD, and entered the RCA.

Prior to reaching Containment-the-technician realized the. mistake, exited the RCA;andl reported the occurrence to the Health _ Physics Shift Technician. The technician rild have both a normal TLD and an electronic ' alarming . dosimeter (PD-1), and he did'not accessithe Containment or any other neutron radiation .

? areas. -As a result, the Technician was monitored correctly lfor the areas he-accessed, and there was no' adverse. radiological consequence to this particular  !

. entry. : The. technician was assigned a-- dose of 0 (zero) ' for _ the questioned '

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entry. e

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l - The ' technician was counseled about his mistake, and allowed to go back to I.

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. work. A Performance Improvement Request (PIR) was initiated to identify, i track,.and. document corrective ~ actions, i-h'

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Attachment to WO 97-0099

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PageL2 of 4 Example Two:

On July 7, 1997,Jan employee, while signing into the Radiological _ Control Area (RCA) - on- Radiation Work - Permit RWP 970003, was distracted = when the Health-Physics Shift Technician asked a question concerning his work. The employee

.then accidentally-left his PD-1 on the reader and entered the RCA with just a TLD. A short time later the employee noticed the absence of the PD-1, exited !

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the RCA and reported to the Health Physics Shift Technician. The PD-1 was then located in one of the storage racks at Access Control. The employee had a TLD, which-is used for legal dose. tracking, in possession at all times. The potential exposure was evaluated, and a dose of zero was assigned. A

' Performance Improvement Request (PIR) was initiated to identify, track, and document corrective actions.

Root Cause The root cause of these events was inattention to detail caused by on the job distractions during RCA sign in process. A contributing factor was the lack of a strong continuing training program for all radworkers.

Corrective Steps Taken and Results Achieved:

Each worker in the examples cited abo'.e notified the Health Physics Shift Technician immediately upon discoverlag the dosimetry discrepancies. This resulted in a potential reduction og exposurc, and allowed Health Physics to evaluate and perform corrective action in a more timely manner.

• - Dose calculations were performed for the two workers. No exposure resulted from these two incidents.

Both workers involved were counseled on the company's. expectations for all workers to follow radiation work practices and procedures. They are now-fully cognizant of the need for not letting distractions interfere with correct compliance, j

Corrective Steps To Be Taken And Date When Full Compliance Will Be Achieved:

• WCNOC is currently monitoring and challenging workers entering the RCA,

~ This _is a- short term ~ action that will .be implemented until further evaluation can be performed.

A stronger emphasis is being placed on initial and requalification training for radworkers.  ?

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e. ~"Just-In-Time" training is being conducted to reinforce- Radiation Protection policies .and supplement radworker training. This training includes a practical factors qualification for radworkers : to demonstrate the correct login, dressout, undress and RCA exit procedures. Personnel currently qualified-as TLD holders are expected to complete this "Just In Time" training by October 2, _1997, or they will not be allowed access to the RCA until the training is completed.

=The Manager of Radiation Protection has given direction for Health Physics department-' personnel to question radworkers on expected standards.

• . In an effort to improve human performance in the Access Control area, WCGS

' Health Physics will submit a propcued facility change to be evaluated using the' design change process. This proposal will be submitted by January 1, 1998.

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Xttechmant to UO 97-0099 Psgo 3 of 4 I*

Violation 50-482/9711-07:

" Title 10 Code of Federal Regulations 50.72(b) (v) requires, in part, that licensees report as soon as practical and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the occurrence of any event that results in a major loss of emergency communications capability.

Administrative Procedure AP 26A-001, " Reportable Events - Evaluation and Documentation," Revision 3 Attachment A, defines a major loss of emergency communications capability as a loss of 3 or more of the 11 emergency plan sirens.

Contrary to the above, on June 16, 1997, at 1:03 a.m., a storm caused 6 of the 11 emergency plan sirens to be inoperable and the licensee failed to report this condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Due to inadequate assessment, the licensee initially believed that only two sirens were inoperable until July 16, 1997, when the event notification was made."

Reason for Violation On June 16, 1997, a severe thunderstorm struck the Coffey County area. At 0130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br />, the Burlington substation, which supplies power to four of the eleven Emergency Preparedness sirens, was struck by lightning and did not supply power to these four sirens for approximately five hours. Power to these four sirens was not completely restored until 0555 hours0.00642 days <br />0.154 hours <br />9.176587e-4 weeks <br />2.111775e-4 months <br />.

It was also determined that there was a momentary loss of power from the Burlington of Burlington.

City substation which supplies power to two sirens within the city I

Since the Burlington City substation has backup power, and was able to quickly restore power to its two sirens, a notification to the Coffey County Sheriff's Dispatcher was not required.

Root Cause The WCGS program for determining when sirens are without power is based on formal letters of agreement between the Coffey County Emergency Preparedness Organization and the utilities supplying the power. Each of the four utilities supplying power to the WCGS sirens are required to notify the Coffey County Sheriff's Dispatcher upon identifying a siren power loss. The required notification of the loss of power from the Burlington substation was not made to the Cof fey County Sheriff's Dispatcher. This was the root cause of the failure to make the one hour notification to the NRC required by 10 CFR 50.72 (b) (1) (v)

It was identified during subsequent investigation that if a WCNOC employee had not awakened during the storm, and questioned the loss of power and its potential effect on .- _ gency sirens, the loss of power to the six sirens would never have been known.

Although the event did not affect the plant or plant personnel safety, it could have impeded the ability to notify members of the public in the event of an emergency classification of a Site Area or General Emergency. Had there been an emergency classification during this time, the backup means of providing notification to the public --- the Sherif f's Department dispatching of squad cars to the affected areas --- would have been used.

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-i-l l Corrective Steps'Taken and Results Achievedt

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The Coffey County Emergency -Preparedness Organization has agreed- to reaffirm the' letters of agreement with each of the. utilities that provide

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t power to the alert and notification system sirens.

e As an aid to_ each utility, -instructions providing guidance for reporting

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l siren power outages were generated by WCGS personnel and given to Coffey

County ' Emergency Preparedness for distribution to the utilities. These

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Instructions are unique to each utility, and contain a list of the sirens.

located within that utility's power distribution system, the power circuit or substation which provides power to each siren, and the phone number of

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the Coffey County Sheriff.

i. e Coffey County Emergency Preparedness has7 agreed to modify the Coffey County l' emergency plan, to ensure there is a firm commitment for the Coffey County l Sherif f's Dispatcher to contact the WCGS Control i'com in the -event of-a loss of power to any.of the Wolf Creek sirens.

i e ~ WCGS has provided to the Coffey County Emergt

, Preparedness organization a -complete list of all eleven sirens' powei sources - for ' use by the

[ Sheriff's Dispatcher, Corrective Steps To Be'Taken And Date When Full Compliance Will Be Achieved:

• To provide a means to quickly and easily identify which sirens are effected by the various power supplies, AI 26A-001, Revision 0, "WCNOC Reportability Handbook"' will be revised to include additional guidance on siren power ~

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supplies. This revision will be completed by October 30, 1997, e

WCNOC 'is evaluating .the benefits of installing ' a system which would allow constant monitoring of the sirens, I

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