IR 05000482/1998011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/98-11 on 980402

ML20247G548
Person / Time
Site:	Wolf Creek
Issue date:	05/11/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-98-11, NUDOCS 9805200279
Download: ML20247G548 (4)

Text

km Mout UNITED STATES t, NUCLEAR REGULATORY COMMISSION

$ REGION IV 611 RYAN PLAZA DRIVE, SUITE 400

/ AR LINGTON, TEXAS 760114064 May 11, 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 98-11 Thank you for your letter of April 28,1998, in response to our April 2,1998 letter and Notice of Violation concerning the proper labeling of radioactive material containers (plastic and cloth bags). We have re iewed 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 maintaine

Sincerely, Blaine Murray, Chief /

Plant Support Branch j Division of Reactor Safety Docket No.: 50-482 License No.: NPF-42 cc:

Chief Operating Officer

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Wolf Creek Nuclear Operating Cor P.O. Box 41 Burlington, Kansas 66839 l

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Jay Silberg, Es Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 Supervisor Licensing Wolf Creek Nuclear Operating Cor ,

P.O. Box 411 1 Burlington, Kansas 66839 9905200279 980511 gDR ADOCK 05000482 PDR

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l Wolf Creek Nuclear -2-Operating Corporation Chief Engineer l

Utilities Division l Kansas Corporation Commission

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1500 SW Arrowhead Rd.

l Topeka, Kansas 66604-4027 l

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

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County Clerk Coffey County Courthouse Burlington, Kansas 66839-1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation l Forbes Field Building 283 ,

Topeka, Kansas 66620 l l

Mr. Frank Moussa Division of Emergency Preparedness I 2800 SW Topeka Blvd Topeka, Kansas 66611-1287

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P Wolf Creek Nuclear -3-Operating Corporation DISTRIBUTION: w/coov of licensee's letter dated Aoril 28.1998:

DCD (IE06)

Regional Administrator Wolf Creek Resident inspector DRS Director DRS Deputy Director DRP Director SRI (Callaway, RIV)-

Branch Chief (DRP/B)

DRS-PSB Project Engineer (DRP/B)

Branch Chief (DRP/TSS)

MIS System RIV File DRS Action item File (98-G-0055)

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DOCUMENT NAME: R:\_WC\WC811 AK.JBN To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:SRS:PSB /E C:DRS\PS S E JBNicholas W BMurray 9 -

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OFFICIAL RECORD COPY

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Wolf Creek Nuclear -3- l Operating Corporation l DISTRIBUTION: w/coov of licensee's letter dated Aoril 28.1998:

DCD (IE06) . *

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

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Branch Chief (DRP/B)

DRS-PSB Project Engineer (DRP/B)

Branch Chief (DRP/TSS)

MIS System )

RIV File DRS Action item File (98-G-0055)

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I DOCUMENT NAME: R:\_WC\WC811 AK.JBN To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:SRS:PjiiB /E C:DRS\PS 5 E l j JBNicholas' W BMurray 9

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05698 V' 05/l198

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OFFICIAL RECORD COPY

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Otto L. Maynard W4#LF CREEK NUCLEAR OPERATING CORPORATION

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President and Chief Executive O*ficer j l

April 28, 1998 WM 98-0038 U. S. Nuclear Regulatory Commission I ATTN: Document Control Desk l Mail Station P1-137 *

Washington, D. Reference: Letter dated April 2, 1998, from Blaine Murray, NRC, to O. L. Maynard, WCNOC

Subject: Docket No. 50-482: Response to Notice of Violation 50-482/9811-0 l Gentlemen: I This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

response to Notice of Violation 50-482/9811-0 Violation 9811-01 identified ,

a failure to label radioactive material container WCNOC' s response to this violation is provided in Attachment If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. Michael J. Angus at extension 407 Ver,y_truly yourg A ' /

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Otto L. fiaynard OLM/rlr Attachment cc: Johnson (NRC), w/a E. Merschoff (NRC), w/a J. Ringwald (NRC), w/a K. Thomas (NRC), w/a

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PO. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 l An Equal Opportunity Employer M FtHCNET

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f , Attachment I to WM 98-0038

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Page 1 of 2 4 4 Violation 50-482/9811-01:

"10 CFR 20.1904(a) requires that the licensee ensure that ecch container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words, ' CAUTION RADIOACTIVE MATERIAL' or DANGER RADIOACTIVE MATERIAL.' The label must also provide suf ficient information (such as the radionuclides present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposure Contrary to the above, on March 19, 1998, the inspector identified seven radioactive material containers (plastic and cloth bags) located in the radwaste storage building, (which contained radioactive material returned from an off-site laundry for disposal) that were not properly labele One container had a contact dose rate of 30 mrem /hr and a one foot dose rate of 8 mrem /hr."

Reason for Violation:

During the receipt survey of a laundry vehicle, two Health Physics Senior technicians detected a 2mr/hr dose rate on the underside of the vehicl The technicians performing the receipt survey and the NRC Inspector observing the evolution discussed the significance of the dose rate. There is no regulatory significance with a 2mr/hr dose rate. Clean laundry generally has dc is rates just slightly greater than background reading The vehicle was staged for the receipt of the incoming material adjacent to the radwaste storage buildin It was determined that the first box unloaded was the source of the elevated dose rates on the traile The laundry box was taken directly to the radwaste storage building for unloading. Several yellow bags labeled as " trash" were removed from the box and surveyed by the attending tect.nicia The dose rates on the trash bags were less than 2mr/h After security inspected the bags, they were piled within direct sight of the attending technician but outside of the direct work are Later, the technician directed the Daconners to take the bags and place them with the other waste bag The last bag unloaded from the container was a magenta laundry ba The bag was labeled with red duct tape and contained the following: dose rate, date and surveyor's initials when generated during our refueling outag The bag was taken directly to the west side of the building, which was unoccupied at the tim Contact dose rate on the magenta bag was 30mR/Lt and 8mR/hr at 12 inche The yellow trash bags and the magenta laundry eg did not have a label indicating " Caution Radioactive Material." The technicians checked the posting of the radwaste storage buildin The building was a posted Radiation Area and a Radioactive Materials Are The technicians were comfortable knowing the radiological hazards (dose rates)

of the material were identifie They were knowledgeable that the material was stored /scaged in a properly posted area. The yellow and magenta colors on the bags identified the material as radioactive n.ateria After the receipt and the subsequent shipping evolution, the Health Physics technicians did not return to the area to relocate or label the bag The magenta laurdry bag remained at the west side of the building and the yellow trash bags were located adjacent to a cart full of trash.

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. Attachment I to WM 98-0038

- . Page 2 of 2 ai Root Cause:

The root .cause of this violation is personnel error because of wrong assumptions made by Health Physics technician WCNOC' s investigation revealed'that no willful procedure violation occurred; however, personnel did not realize that the procedure requirements applied to this specific situatio The technicians assumed that since the area was properly posted in accordance with Procedure RPP 02-215, " Posting of Radiological Controlled Areas," the bags themselves did not require additional labeling. This mindset j was the major contributor to the personnel erro The technicians believed that labeling of the bags would have been redundant because they were beino placed in the posted are {

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Contributing cause:

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Confusion existed in the definition of, " container," with regard to bags used within the radiologically controlled area to transport and store radioactive materia Procedure RPP 02-215 does not provide clear guidance in this are '

Corrective Steps Taken and Results Achieved:

• Upon notification by the NRC Resident Inspector on March 19, 1998, the seven j bags were properly labelec'. j,

• Performance Improvement Request (PIR) 97-0791 was initiated to evaluate this event and to develop a corrective action pla * The Superintendent Radiation Protection issued letter HP 98-004, " Interim Corrective Action PIR 98-07 91," : on April 8, 1998, to all Health Physics personnel to provide . interim guidance on radioactive material container labelin This letter stated that all bags containing radioactive material shall be treated as a radioactive material containe * The individuals inv.olved were counseled on the importance of procedure reviews prior to beginning a job evolutio _

Corrective Steps To Be Taken:

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• Procedure RPP 02-215 will be revised to provide guidance that bags are to b considered radiological material containers and labeled accordingl This action will be complete by June 1, 199 e. The Health Physics technician continuing training cycle will include testing on procedures to ensure a clear understanding of procedures and their inten This action will be complete by August 6, 199 Date When Full Compliance Will Be Achieved:

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Full compliance was achieved on March 19, 1998,- when the seven bags were properly labeled as radioactive material container .

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