IR 05000482/1998009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/98-09

ML20217K288
Person / Time
Site:	Wolf Creek
Issue date:	04/28/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-98-09, 50-482-98-9, NUDOCS 9805010141
Download: ML20217K288 (4)

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>S "'%Q UNITE D STATES f$ g NUCLEAR REGULATORY COMMISSION

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[f, 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TE XAS 76011-8064 April 28,1998 Otto L. Maynard, President and ,

Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 SUBJECT: NRC INSPECTION REPORT 50-482/98-09 AND NOTICE OF VIOLATION

Dear Mr. Maynard:

Thank you for your letter of April 10,1998, in response to our March 13,1998, letter and Notice of Violation concerning a release of radioactive material from the radiological controlled area. 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.

Since ly, l

Blaine Murr y, C ief Plant Sup Branch Division of Reactor Safety Docket No.: 50-482 License No.: NPF-42 cc:

Chief Operating Officer ,

Wolf Creek Nuclear Operating Corp.

P.O. Box 411 j Burlington, Kansas 66839 Jay Silberg, Esq. l Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 9005010141 990428 PDR ADOCK 05000482 l G pog

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Wolf Creek Nuclear Operating Corporation -2-Supervisor Licensing Wolf Creek Nuclear Operating Corp.

~ P.O. Box 411 Burlington, Kansas 66839 _

Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhem1 Rd.

Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 Attomey General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66612-1597 County Clerk Coffey County Courthouse Burlington, Kansas 66839-1798 Vick L. Cooper, Chief Radiation Control Program i Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field Building 283 l Topeka, Kansas 66620 Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611-1287

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Regional Administrator WC Resident inspector DRS Director DRS Deputy Director DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B)

DRS-PSB Project Engineer (DRP/B)

Branch Chief (DRPfrSS)

MIS System RIV File DRS Action ITEM (98-G-0046)(Goines)

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W$LF CREEK !

NUCLEAR OPERATING CORPORATION l

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Presscent and Chief Executive Officer [,,Dq j -[-

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April 10, 1998 )

WM 98-0034 I (

l U. S. Nuclear Regulatory Commission l ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555 l Reference: Letter dated March 13, 1998, from Blaine Murray, NRC, to O. L. Maynard, WCNOC Subject: Docket No. 50-482: Response to Notice of Violation 50-482/9809-03.

Gentlemen:

This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

respense to Notice of Violation 50-482/9809-03. Violation 9809-03 identified that proper surveys were not performed to prevent the unconditional release of radioactive material from the Radiologically Controlled Area (RCA).

WCNOC's response to this violation is provided in Attachment I. If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. Michael J. Imgus at extension 4077.

Very truly yours,

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l Otto OLM/rer Attachment cc: W. D. Johnson (NRC), w/a l E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a K. M. Thomas (NRC), w/a l

l 9 8- IZZZ P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity E,notoyer M/F/HC/ VET

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• Attachment I to WM 98-0034  !

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Violation 50-482/9809-03:

" Technical Specification 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, l February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e.4, recommends procedures for radiation surveys.

i Procedure RPP 02-515, " Release of Material From the RCA,' Revision 9, j Section 6.1, states, ' Thorough surveys must be performed to prevent the 1 unconditional release of materials greater than the release criteria.'

Section 4.5 establishes the release criteria. The first criterion states,

' Beta-gamma shall be non-detectable for loose (smear /100cm) and fixed plus loose as measured with RM-14 with an HP-260 or equivalent-.'

Contrary to the above, proper surveys were not performed to prevent the unconditional release of radioactive materials greater than the release criteria. Specifically, a remote monitor detectcr head was released from the radiological controlled area on December 8, 1997 with loose beta gamma contamination measuring 600-1500 disintegrations per minute /100 cm2 and fixed radioactive material measuring 15,000 disintegrations per minute /100 cm as measured with an RM-14 with an HP-260 or equivalent."

Reason for Violation:

On February 25, 1998, Wolf Creek Generating Station (WCGS) personnel were notified by Fermi plant personnel that one of the fifteen Science Applications International Corporation (SAIC) Model PDE-4 remote communicating personal electronic dosimeters borrowed by WCGS, and later returned to Fermi, was contaminated. This equipment had been released from the WCGS Radiologically Controlled Area (RCA) on December 8, 1997. It was later determined that the actual contamination was restricted to one face of one of the extremity detectors attached to the PDE-4 dosimeter. The total activity, including both loose and fixed contamination, was 1.42 x 10-4 micro-curies per gram. This small amount of loose and fixed contamination was below that required for reporting, and the potential fnr a hazard to human health was minimal.

The SAIC Model PDE-4 dosimeter is a remote communicating personal electronic dosimeter. Four extremity cables, with detectors to monitor different body locations, can be attached to each Model PDE-4 dosi.ne te r . The SAIC Model PD-4 and Model PDE-4 dosimeters were borrowed from the Fermi plant, before the start of WCGS Refueling Outage Nine, with the intention of returning them after the outage.

On December 8, 1997, Model PDE-4 dosimeter with serial number RE1064 was unconditionally released from the WCGS RCA, along with fourteen other dosimeters, power packs, and extremity cables with extremity detectors and transmitters. Gae of the extremity detectors (serial number XS223) of dosimeter ,

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RE1064 was later found be contaminated when it was surveyed by personnel at the Fermi plant. The contaminated extremity detector with extremity cable and dosimeter was stored in the Health Physics instrument calibration area until 3

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February 18, 1998, when it was shipped to the Fermi plant.

Fermi plant practice is to perform a radiological survey when the plant receives equipment or material from other nuclear plants. In performing this survey on the returned dosimeter equipment, Fermi personnel found contamination on detectcr #XS223, which was paired to PDE-4 #RE1064. All other equipment checked was free of contamination. Fermi informed NRC Region III, and then notified WCGS on February 25, 1999.

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, , Attachment I to WM 98-0034

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The technician who originally surveyed the contaminated detector at WCGS, and released it from the RCA, was interviewed to determine why the contamination was not detected. Although it is documented that he released PDE-4 serial number RE1064, no documentation was found that showed the individual extremity detector being released. Later discussions with the technician determined that the extremity cetectors were released as a unit with the PDE-4 dosimeter.

In the interview, the technician stated that he performed loose contamination surveys and noted contamination. The equipment was found to be contaminated from 1000 disintegrations / minute (dpm) up to 20,000 dpm. He then performed decontamination to clean up the equipment. After decontamination, the equipment was resurveyed and no contamination was detected by direct frisk.

Smears of the equipment were taken, and counted on a MS-3 scaler, and no contamination was detected. As a final check, the technician then placed each unit, with cables and detectors, one unit at a time, into the TCM-2 tool contamination monitor. No contamination was found. The PDE-4 dosimeters, with cables and detectors, were released from the RCA to the Health Physics Calibration Lab. The technician also stated he did not feel that he was under any time pressure to complete the release process; however, he did experience interruptions during the process.

Root Cause:

The root cause of this event was human error in performing contamination surveys of multiple items at a time. The contamination was identified on extremity detector #XS223, which was attached to remote communicating personal dosimeter PDE-4 # RE1064.

One individual performed the surveying and release of this material. The results of investigation indicate that the technician appropriately followed procedure requirements to release material from the RCA, and should have detected the loose contamination. With multiple PDE-4 remote communicating personal dosimeters being surveyed, each with up to four extremity cables and detectors, the most probable cause for missing the contaminat' ion on extremity detector #XS223, was confusion as to which extremity detector (s) had been surveyed. A contributing factor included disruptions of the survey work due to external distractions.

Corrective Steps Taken and Results Achieved:

• The Health Physics Supervisor Support was notified. Information about the serial number of the instrument and the isotopic content of the contamination was requested from Fermi.

• Upon initial notification from Fermi, the following actions were initiated:

1) A survey was performed of the WCNOC Health Physics Calibration Lab where the detector had been stored. No contamination was found.

2) Wolf Creek Generating Station personnel requested the Fermi plant to ship the extremity probe back to WCGS so that further analysis could be performed.

3) The NRC Resident Inspector was notified, and a NRC Region IV Radiation Specialist (who was onsite at the time performing Inspection 98-09) was informed of the information obtained from Fermi.

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Attachment I to WM 98-0034 a' .

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4) PIR 98-0504 was initiated to document and track investigations of the I incident. As a part of this investigation, it was determined that the incident was not reportable to the !;RC or Department of Transportation.

• The technician responsible for releasing the contaminated item was counseled on remaining focused during the release process, and on minimizing the j number of items he is working on during the release process. j I

Corrective Stops To Be Taken:  !

• To further enhance Health Physics Technician awareness of potential pit falls while releasing material from the RCA, training with a mock-up will be performed. This awareness enhancement training will be completed by July 1, 1998.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved en February 25, 1998, when the contaminated l instrument was identified by Fermi personnel, and was subsequently controlled by and within the Fermi radiation protection program.

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