IR 05000482/1998010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/98-10

ML20249A956
Person / Time
Site:	Wolf Creek
Issue date:	06/15/1998
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-98-10, NUDOCS 9806190188
Download: ML20249A956 (4)

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e e pa afc UNITED STATES og$t

1. 1 NUCLEAR REGULATORY COMMISSION l

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REGION IV

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[ 611 RYAN PLAZA DRIVE, SUITE 400

1. '5 ARLINGTON, TEXAS 760118064

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JUN I 51998 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 SUBJECT: NRC INSPECTION REPORT 50-482/98-10 AND NOTICE OF VIOLATION

Dear Mr. Maynard:

Thank you for your letter of June 5,1998, in response to our letter and Notice of Violation concerning failure to properly post and barricade the entrance to a high radiation 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. We appreciate the perspective you provided concerning irradiated specimen handling and the operations evolution checklist.

Sincerely,

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W. D. Johnson, Chief l Project Branch B [/

Division of Reactor Projects /

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Docket No.: 50-482 License No.: NPF-42 cc:

I Chief Operating Officer )

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Wolf Creek Nuclear Operating Corp.

P.O. Box 411 Burlington, Kansas 66839 l 9806190188 980615 PDR l

0 ADOCK 05000482

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J Wolf Creek Nuclear Operating Corporation -2 ~

, -Jay Silberg, Esq.

. Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW .

,_ Washington, D.C.' 20037 i.

Supervisor Licensing .

Wolf Creek Nuclear Operating Corp.

P.O. Box 411

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Burlington, Kansas 66839 l Chief Engineer Utilities Division s Kansas Corporation Commission 1500 SW Arrowhead Rd.

Topeka, Kansas 66604 4 027 .<

Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66612-1597 County Clerk

. Coffey County Courthouse Burlington, Kaneas ' 66839-1798 Vick L. Cooper, Chief Radiation Control Program 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 2800 SW Topeka Blvd Topeka, Kansas 66611-1287

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'!UC'_3AA CPE .ATING CORPORATION Otto Presicent and Chief Executive Officer J$l - 9 JUN 5 1998 t

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WM 98-0049 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C. 20555 Reference: Letter dated May 6, 1998, from William D. Johnson, NRC, to O. L. Maynard, WCNOC Subject: Docket No. 50-402: Response to Notice of Violation 50-482/9810-11.

i Gentlemen:

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

response to Notice of Violation 50-482/9810-11. Violation 9810-11 identified a failure to properly post an area that permitted access to a high radiation area with dose rates of approximately 400 mrem /hr and immediate corrective actions which failed to barricade the entrance. This letter also provides discussion of issues concerning the use of the Operations Evolution Checklist and the use of pre-job ALARA checklists.

WCNOC's response to this violation and the aforementioned discussion are provideo in the attachment. If you have any questions regarding this response, pleasc contact me at (316) 364-8831, extension 4000, or Mr. Michael J. Angus at extension 4077 Very truly ours, !

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y Otto L.' Maynard OLM/rir i Attachment

c: M. 2. Johnson (MRC), w/a E. W. Merschoff 'NRC), w/a J. T. Ringwald (MRC), w/a

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O S x 411 Suninoton. n5 66839, Phone: 1216) 364 6831

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. Resoonse to Violation 50-482/9810-11 i

violation 50-482/9810-11:

"Tecnnical Specificatica d. R recuires, ;n part, :nat nigh raciation areas in j which the intensity of racia:1cn is equal or less than 1000 mR/h at 45 cm (18 ~

in.) from the radiation source shall be carricaced and conspicuously posted as  ;

a high radiation area.  !

i Contrary to the aoove, en April 10, 1998, an accessible high radiation area on  !

he radwaste building roof witn a cose rate of approximately 400 mR/r at 18 l in, was not posted as a high raciation area anc, when it was discovered and i posted as a nigh radiation area, was not barricaded."

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Description of Events: i

During a routine walkdown by a Health Physics supervisor on Friday, April 10, f 1998, . a scaffold to the outside of the Radwaste Storage Building was found '

posted " Radiation Area--Contact HP Prior to Entry." The supervisor questioned i if the Radwaste Building roof was accessible from the Radwaste Storage Building j roof, and if dose rate surveys hac been performed. Review of the documentation J incicated that :ne Radwaste Storage Eu11 ding roof had been surveyed on March 26, 1998. However, the Radwaste Building roof had not been surveyed. A Health l!

Physics technician was dispatched and determined that the roofs were accessible to each other, and surveyed the Radwaste Building roof. That survey indicated dose rates from 80 mrem /hr up to 500 mrem /hr on the Radwaste Building Roof.  ;

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The area was subsequently posted as a High Radiation Area (HRA) on April 10, 1998. The area was not barricaded to prevent inadvertent entry to the roof ,

area until later that evening when it was recognized the posting was l inadequate. Therefore, the Radwaste Building roof was accessible to station i personnel from March 26, 1998, through April 10, 1998. Logs were reviewed to determine if the root- had been accessed. The logs indicated the Radwaste Storage Building roof was accessed on April 7, 1998, to perform maintenance on an air conditioning unit; however, a survey was conducted and work area dose rates were <2 mrem /hr. An HP tecnnician was present during that time to ensure the dose remained ALARA.

Reason for Violation:

The root cause ;f both examples in :nis violation involvec personnel error.

The mindset of the individuals involvec resultec in inacequate evaluation of a condition, followed by inacequate decision making in correcting the adverse

endition. A dose gracient was identified curing the initial survey of the Raawaste Storage Building r:of near ne Radwaste Building roof. The decision was mace to utilize continuous Health Physics coverage to maintain ALARA and to ensure the postings were not clown ff the roof. This a:: ion was taken to prevent personnel from entering areas of elevated dose rates. Althougn station personnel were kept away from tne Raowaste Building roof, :he entrance was not posted anc barricaded to prevent unauthorized entry into a High Radiation Area.

Nith respect :o the failure to acequately carricace the identified high raciation area, the Senior Health Physics Tecnnician cispat:ned to cctain the

0se rates and :: properii p st access ;o tne :cf hao a fear of heignts. This fear :reatec anxiety inc  ;;nrusion, preventing him from satisfactorily

mpleting the task. However, :ne :sar was not made known .o Health Physics sur;e rvisi on .

ne:ner ::ntributinc facter :: -.e :11.cre was ne minaset :f a Junior Healtn

tysics Tecnnician sent :: veriti p stings. The Junior Tecnnician _imited nis

eview

: :nly ne postinc _nserts. ~he incivicual rellec :n ne ucqment of

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Attachmant to WM 98-0049

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- the - Senior Health Physics Technician, rather than objectively questioning if the-area was properly posted and barricaded.

Corrective Steps Taken and Results Achieved:

On April 10, 1998, at 1630 - hours,' the scaffolding leading to the Radwaste t

Storage Building roof was posted, "High Radiation Area-notify HP prior to l - entry; specific Radiation ~ Work Permir- (RWP) . required for entry," after dose rates were found to be >100 mR/hr. After the area was discovered posted as a-High Radiation Area (HRA) without a barricade, the accessible sides of the ladder were then barricaded and two additional postings were hung. This action was completed on April 10, 1998, at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br />.

Health - Physics personnel reviewed the shift logs and surve} s to determine if

. the roof had been accessed. This review indicated that the roof had been '

accessed on April 7, 1998; a . survey performed during that activity indicated that the work-area dose rates were <2 mrem /hr.

An investigative team was formed to examine other similar events that have recently - occurred. Interviews were conducted to determine if generic human

~ performance - factors were hindering performance. No generic human performance errors related to these events was discovered. However, the team did provide

- recommendations for enhancing human - performance in the Health Physics area.

This information was. captured in Performance Improvement Request 98-1027. The results of,the interviews are being reviewed by an industrial physiologist to

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- confirm the team's findings. l Other areas- in- the plant -were reviewed to determine if similar access conditions existed. None were identified.

Corrective' Steps To Be Taken:

B'ased on- the investigative t eam' s findings and recommendations, a Health Physics supervisor will serve-as a field coach for the remainder of 1998.

Date When Full Compliance Will Be Achieved:

. Full compliance was . achieve'd when- accurate pcatings and barricades were :

--installed on the Radwaste Storage Building roof, and the ladder'to access the ]

roof, on April 19,11998, at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br />. J ALARA Checklists and Irradiated Specimen Removal Paragraph thirteen of the Executive Summary and section R3.1 (page 18) -of the report summary provided discussion associated to the use of ALARA checklists and contingency plans for - the irradiated specimen shipment. The inspection l-

' discusses a process wnere movement of an irradiated reactor vessel specimen was L Leo be' performed. The report documents contingency actions of grasping the 4 specimen by hand to physically assist inserting the specimen into a cask should the need arise. The remainder of the inspection report discussion is based on

.this^ action. ,

WCNOC's Pre-Job Briefing addressed the contingency if the specimen movement was stopped or if problems came up during the move. Inspection. Report 98-10 stated that the contingency plan . was to grab the specimen by hand. However, the p

l Reactor = Engineer actually . stated he would grab the long handled specimen removal. tool to physically insert the specimen into the shipping cask. During the Pre-Job Briefing evaluation, the potential dose to insert the specimen with Ethe long handled tool was evaluatec. Time was estimatea by the individual to be 30 seconds. Health Physics personnel calculated a dose of 133 mrem to the Whole Body based en one minute. 'Therefore, the coses would not have been

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, within the range necessary to warrant the use of the ALARA Checklist.

Procecure AP 25B-300, "RWP Program," does not require an ALARA Checklist be initiated if the : tal dose f r -he ::b is less than 1 man-rem.

J2-105, "RWP,"

However, RPP requires a Pre-J0c Briefing f:: any work performed in or with access to a Locked Hign Radiati:n Area (LHRA) ::, a Hot Particle Area (Zone 3).  !

The dose rate anticipated from the specimen was up to 30 rem /hr, which qualified it to be classified as a LHRA. The spent fuel pool in which the specimen was stored is a posted Hot Particle Area. Based on the potential risk associated with the f0b the HP Supervisor required a Pre-Job Briefing. A specific RWP was initiatec basec cn a LHRA and potential risk.

The intent of the ALARA Checklist is for the Job Coordinator and the work group ALARA Representative to use the enecklist during the pre-planning of the job.

The Pre-Job Briefing form (APF 25B-300-08) is used to ensure that all radiological aspects of the job are considered. Its purpose is to ensure jobs that have a high risk potential are evaluated, even though the dose expended may be minimal. The Pre-Job Briefing for this job adequately covered items '

considered on the Pre-Job ALARA Checklist.

Conclusion:

The PRE-Job Briefing more than adequately addressed the radiological concern associated with this ;oo even though the total dose received was less than 0.050 man-rem. There were no procedural requirements to perform a Pre-Job ALARA checklist.

The presumption documented in the inspection report is based on a miscommunication between the system engineer and the inspector. At no time did the work documents provide for grasping the specimen by hand. Therefore, the doses would not have been within the range necessary to warrant the use of the )

ALARA Checklist. In addition, the activities associated to the pre-planning and pre-job briefing were equivalent to the activities performed with the checklist.

Use of Ooerations Evolution Checklist '

Paragraph four of the Executive Summary and Section 07 (page 4) of the report summary provided discussion essociated to Self-Assessment Report SEL 98-003,

" Effectiveness of the Cperations Evolution Checklist." The inspection report presents a position that, :ue tc cnanges recommenced from t..e Self-Assessment ceing incorporated, :ne enecklist hac become less effective.

The Cperations Evolution Checklist was originally developed for use when a crouoleshooting request c: a request to perform a prouedure is received to help ensure complete communications take place. From interviews with personnel using the checklist, it has been determined that some of the questicns are not applicable, some are 0;verec procedurally in AP 21-001 "Cperations Evolution Practices", or are coverec in tne work package. Some of the questions are the responsibility of tne personnel requesting permission to perform the activity anc the accountability for : nose items rests with that person and their supervisor. The revised " Evolution Screening Checklist" provides a more acncise list cf questiens that ensure complete communications take place prior

performing the activity.

l he Evolution Screening Checklist is usec as a tool to prompt ::mmunication and

nougnt processes. The recemmencations mace in the Self Assessment provided ,

i:r cetter alignment :f the checklist with the actual processes anc made the l

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necKlist a more useful :ol. :: is WCNOC's belief that the checklist remains sfie:::ve anc vill re usec 1r : .e :uture wl:h meaningful results.

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