ML20198N219
| ML20198N219 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/14/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-97-20, NUDOCS 9801200294 | |
| Download: ML20198N219 (4) | |
See also: IR 05000482/1997020
Text
e
- N8 %g UNef tD STAf tS
- .ff.jf ft NUCLEAR REGULATORY COMMIS$10N
I .\jk) ,I ntosoN av i
t $11 RYAN PLAZA DAIVE, SulTE 400
%f ,, "' , ,o ARLINGTON, T E xAB 76011 A064
January 14, 1998~
>
i
. Otto L Maynard, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.0, Box 411 !
Buriington, Kansas 66839
SUBJECT: NRC INSPECTION REPORT 50-482/97 20 AND NOTICE OF VIOLATION
Dear Mr. Maynard: !
Thank you for your letter of December 12,1997, in response to our letter and Notica of Violation
dated November 14,1997. We reviewed your reply and requested additionalinformation during
a telephone conversation on December 31,1997, between M. Blow of your staff and
'
L Ricketson of Region IV. After reviewing the information in your response and that provided
during the telephonc conversation, wu find your actions responsive to the concems raised in our
Notice of Violation.
With respect to Violation 50-482/9720 02, we understand that, in addition to the focused
corrective actions described in your letter, you addressed the violation more broadly by
discussing the procedural requirements for conditionally releasing items from the radiologically
controlled area with the entire operational health physics staff,
With respect to Violation 50-482/9720-03, we understand that your corrective actions will
address the identified root cause of the violation, which was the vague procedural guidance. We
'
understand that you will not only perform evaluations of the items discussed in your response,
but you willimplement revisions to trect any shortcomings identified.
If we have improperly characterized your corrective actions, please contact us for additional
discussion. 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,
t
~
1 1
M Blain Murray, Chief \
-
$ Plant Support Branch
Division of Reactor Safety (
cc: i
Chlef Operating Officer . '
,
- '
Wolf Creek Nuclear Operating Corp.
P,0. Box 411
m ,Burlington, Kansas 66839
Rlllllll,5Ellll
.
l
,T*288&t !!8%
!
'
- """ -
.
. _
. _ - _
_ ..
.-
!
, .
'
Wolf Creek Nuclear Operating Corporation -2
Jay Silberg, Esq. f
Shaw, Pittman, Potts & Trowbridge l
'
2300 N Street, NW -
Washington, D.C. 20037
Supervisor Lloonsing !
-
Wolf Creek Nuclear Operating Corp.
P.O. Box 411 i
Buriington, Kansas 66830 ,
5
Chief Engineer
Utilities Division i
Kansas Corporation Commissico
1500 SW Arrowhead Rd.
Topeka, Kans.es 66004 4027
Office of the Govemor
State of Kansas t
Topeka, Kansas 66612 l
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 :
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
l 2800 SW Topeka Blvd
L Topeka, Kansas 66611 1287-
1
i
,
f
j.-
, _ . _ _ _ .- . . . . . - ~ . .
. .
_ _ _ _._ , . . . _ . _ . . . _ _ _ _ _ _ . _. _ . _ _..___~
+ 's . 1 '
...-
~
,
i
.4
,
T
_
,
...
Wolf Creek Nucieer Operating Corporation -3-l {
e
!
DISTRipuTION w/ mpy of licannan's letter dated December 12.1997: ;
DMB (IE06) ;
. Regional Administrator - .
Wolf Creek Resident inspector ' l
DHS Dweetor .i
DRS Deputy Director.
DRP Director ,
-
DRS-PSB
. SRI (Callaway, RIV) ;
Branch Chief (DRP/B) -l
Project Engineer (DRP/B) !
Branch Chief (DRPF7' i
MIS System - :
RIV File .
-
L Ti Ricketson, DRS/PSB - -;
'
. i
L At 97-G 138 .
}
!
t
t
h
-!
i
.!
o
,
I
- >
'
,
-
r
&
4
i
'
DOCUMENT NAME: G:\ REPORTS \WC720AK LTR
7. e.ema oopy or e wn ni. inmeme in bon: c = copy m enciosum a = copy ws, .ncio um v = No cay - ,
'
RIV:PSB -1 _
C:DRIMP99, C:DRP\B ,
-
LTRicketson:nh D BWlurW L BJohnson PW i
01/1/98 01/g98 - I 01/M98
'
,
. OFFICIAL RECORD COPY
I
,
'
p- l
.
.
- ,
~
-
-
-
.,~.,,._._m.,_ .,m,< .. . . . . _ . .. .,# r#,_._
. .,. . . , , . _ , , ..._ . . . .
. - _ _ _ . - - . ._ ______ _- _ . _ _ _ - _ _ - - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ _ - _ _ _ _ .___-. __ _ _ _ - _ _ _ _ - _ - ._
,
.
}
Wolf Creek Nuclear Operating Corporation - 3-
Ql1TRIBUTION w/emy of skannee's letter da*M December 12.1997: ,
- DM8 (IE06) :
Ragional Administrator
Wolf Creek Resident inspector
DRS Director
DRS Deputy Dir'ector
DRP Director
DRS PSB
SRI (Callaway, RIV) :
Branch Chief (DRP/B)
Project Engineer (DRP/B)
Branch Chief (DRP/TSS) .
MIS System ;
RIV File :
!
L T. Ricketson, DRS/PSB
- Al 97-G 138 ,
!
,
t
DOCUMENT NAME: G;\ REPORTS \WC720AK.LTR
.
To rocsive e.opy of document, indkate in boa:"C" = Copy without enclosures *Eae Copy wth er closures *N" = No copy
RIV:PSB _ C:DRSPR C:DRP\B ,.
LTRicketson:nh D BMurM}h BJohnson '
M
01/1/98 01/g98 I 01/W98
OFFICIAL RECORD COPY
200ngg
.
+
. . . , - . . . _ . - , --~m-m+ , - - . --e-wr-E-n..m - - * , = -
._ - .- - - -. _ _.
.,
.
,
.
i
W%F CREEK NUCLEAR OPERATING CORPORATION
m
Clay C. Warren
Chef Operating Officer ~R , l n,'-
i- ., ya <
h9 f,4
t ; .1 ,, ---
b 't -,: )l
,
liial. l 6 hGT 7
I
l ~'
' ,
December 12, 1997
,. '
,_
U. S. t1uclear Regulatory Commission
ATT11: Document Control Desk
Mail Station P1-137
Washington, D. C. 20555
Reference: Letter dated 11ovember 14, 1997, from A. T. Howell III,
NRC, to 0. L. !!aynard, i?C110C
Subject: Docket tio. 50-482: Response to flotice of
Violations 50-482/9720-01, 9720-02, and 9720-03
Gentlemen
This letter transmits Wolf Creek 11uclear Operating Corporation's (WCriOC)
response to Notice of violations 50-482/9720-01, 9720-07, and 9720-03.
Violation 9720-01 cites a failure to post and control a locked high radiation
areas Violation 's720-02 addresses a failure to track and label items
containing radioactive materials and Violation 9720-03 identifies a failure to
conspicuously post a contaminated area.
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-
883*., extension 4485, or Mr. Michael J. Angus at extension 4077.
Very truly y urs,
.IiT *W%%4 a
l
Clay C. Warten V
Attachment
cc W. D. Johnson (NRC), w/a
E. W. Herschoff (NRC), w/a
J. F. Ringwald (NRC), w/a
K. M. Thomas (NRC), w/a
} R- D dh'h b
PO Don 411/ Burhngton, KS 66839 / Phone:1316) 364 8831
MMM i[p An Eauni Cmors u rwty Envovw M FmvCT
..
Attcchm:nt to UO 97-0133
. Fage 1 of 8
Violation 50-482/9720-01:
"10 CFR 70.1003 defines a high radiation area as an area, accessible to
individuals, in which radiation levels could result in an individual
receiving a dose equivalent in excess of 100 milliren.s in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30
cantimeters from the radiation source or from any surface that radiation
penetrates. 10 CPR 20.1902(b) requires the licensee to post a high
radiation area with a conspicuous sign or signs bearing the radiation
symbol and the words, ' Caution, high radiation area.'
Technical Specification 6.12.2 requires, in part, that areas accessible
to personnel with radiation of greater than 1000 millirems per hour
shall be previded with locked doors to prevent unauthorized entry or,
where no enclosure exists for the purpose of locxing and no enclosure
can be reasonably constructed around the individual area, that
individual area be barricaded, conspicuously posted, and a flashing
light shall be activated as a warning device.
Contrary to the above, October 12-13, 1997, an area above filter THBil
with radiation levels greater than 1000 millirems per hour was not
conspicuously posted as a high radiation area and a flashing light was
not activated as a warning device."
Reason for Violation:
During routin9 replacement of the FHB11 filter, the wotk was stopped due to a
broken cover telt (one of four). At shift turnover, the job was left for the
oncoming crew to replace the broken bolt, once an engineering disposition was
received, and then to continue with completion of the filter change-out in
accordance with the work package. The oncoming crew supervisor was directed
by Outage Control Center personnel to torque the three bolts, so the system
could be returned to service. The decision was based on the need to support
Refuel Outage IX activities.
Maintenance per.sonnel tightened the three bolts, and signed off the work.
package as complete, with annotations by the supervit,or that only three tolts
were tightened, and that WCNOC Operations personnel would replace the shield
p!"g,
The unit was leak tested and placed in service at 2:30 AM en October 13, 1997.
I.: approximately 1:00 FM on October 13, 1997, it was discovered that the
shield plug had not been replaced. This condition went undetected, and the
radiation levels began ircreasing af ter the filtration unit was placed inte
service.
Dose rates gradually increased until the condition was discovered,
approximately ten hours later. Dose rates at that time were found to be ten
REM per hour on contact, and three REM per hour at twelve inches. This
condition had the potential to cause significant personnel radiation exposure;
however, no significant exposure was recorded because of the event.
Root Cause
The root cause of this event was failure of individuals to follow the
renuirements of maintenance procedure MCM M723Q-01, Revision 9, "NSSS Filter
Changeout."
__. ,_
..
'
,,
.. A~tcchment to CO 97-0133
- - Page 2 of 9
Contrikuting Factors
The following causal factors contributed to the failure to follow the
requirements of procedure M2M M7230-0A.
e A Maintenance past practice of allowing individuals outside the Maintenance
department to complete procedure work steps for them.
- A failure of Maintenance personnel to adhera to the admir.istrative
requirements of procedure AP 15C-002, " Procedure "se and Adherence."
e A failure by the individuals involved to communicate the need for actions
to assure the work was completed in a satisfactory manner.
Corrective Steps Taken and Results Achieved: I
e When the condition was identified, the Shift Supervisor, Health Physics
Shif t Technician, and Health Physics Supervision were immediately informed.
Health Physics personnel surveyed and posted the area, then secured the
area by having the shield plug replaced.
- Procedure GEN 00-030, Revision 16, " Solid Radwaste System Filter Change"
was revised on October 14, 1997, to add specific direction to operators for
installing the shield plug.
- On December 4, 1997, procedure MCM M7230-01 was revised by On-the-Spot-
Change (OTSC) 97-0829, to cover only the steps which Maintenance persor.nel
perform.
- The Superintendent Chemistry / Radiation Protection reinforced nanagement
expectations regarding communications with Health Physics personnel dur'ng
a two hour stand down period ,n October 14, 1997. This session included
b3th in house and cor'.ractor technicians. The Superintendent
Chemistry / Radiation Protection einphasized the need to apply focus on work
expectations, to be intrusive, and to demand to be notified of system
changes.
e On October 14, 1997, the Superintendent Chemistry / Radiation Protection also
gave directirn to the Health Physics organization to not allow the filter
shield plur to be removed, in the future, without continuouc Health
Physics covs age. Administrative Procedure AP 25A-200, " Access to Locked
High or Very High Radiation Areas" was revised on November 18, 1997, to
reflect this direction,
e On November 6, 1997, the Manager Maintenance gave training to all
Maintenance Sepervisors and workcts, to reinforce:
1. That procedures must be followed, even if told something different
2. That workers should never allow anyons in authority to give direction
which would cause a violation of procedures;
3. That workers should never allow another organization to perform work you
are responsible to performs-
4. That supervisors are allowed to annotate steps not performed in a
proceduro only if not performing the step has no affect on ths outcome
of the work activity; and,
. . . _ .
'
...
'
. Attachm:nt to WO 97-0133
- . Page 3 of 8
5. The nead for better communications when exceptions to routine activities
are encountered.
Corrective Pteps To Be Takent
- A supplement to Performance Improvement Request (PIR) 97-3199 will be
developed to document the actions taken to clarify the requirements for-
placing non-cenforming equipment into service. This clarification will be
communicated to site persor.ael by February 1, 1998.
Date When rull Compliance Will Be Achieved:
At approximately 100 PM on October 13, 1997, it was discovered that the
shield plug had not Jeen replaced. The area was immediately surveyed by
Health Physics, and proper postings established. This posting re-
established complj ance to 10 CFR 20.1902 (b) and Technical Specification 6.1
2.2 on October 13, 1997.
- - . .- __ _ - _ _ _ _ _ - ._ . _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _
_ _
_ _ - _ _ _ __ _
1
I- *
.
'
. Attcchm:nt to WO 97-0133
.
Page 4 of B.
Violation 50-482/9720-02:
" Technical Specification 6.8.1.a requires, in part, t hat written
procedures be established, implemented, and maintained covsring the
procedures recommended in Appendix A of Regulatory Guide 1.33, Revision
2, February 1978. Section 7.e.(4) lists radiation protection procedures
for contamination control. ...
Procedure RPP 02-515, 'Pelease of Material From the RCA,' Revision 8,
Section 9.4.1 states, in part, ' Material 110T meeting the unconditional
release criteria may be taken outside the normally established RCA. Form
RPF 02-515-02 is used for conditional release of items.' Section 9.4.1.d
states, in part, "The item must be labeled . . . .'
Contrary to the above, Snubbers 17994 and 20231, items not meeting the
normally
unconditional release criteria were taken outside the
established radiological controlled area on October 12, 1997, without
using Form RPF 02-515-02 and without being labeled to dentify the
presence of radioactive contaminatior."
Raason for Violation:
On October 12, 1997, a Health Physics sechnician conditionally released two
snubbers from the Radiologically Controled Area (RCA) using form RPF 02-210-1,
"WCGS Radiological Survey Map." The correct form for conditional release of
material from the RCA is RPF 02-515-2, " Conditional Rolease Form."
Investigation identified that the individual received a call from the Health
Physics Shift Technician with information that tuo workers would be needing
snubbers released from the RCA. The snubbers aere to be installed in Area 5
(main steam enclosure) which is normally a part of the RCA, but had been
temporarily released f rom the RCA to support main steam isolation valve work
for Refuel Outage IX. The correct procedure, RPP 02-515, Revision 8,
" Release of Material f rom the RCA," was provided to the individual by the
Shift Technician, and the individual was told to release the snubbers if they
were radiologically acceptable. Upon surveying the snubbers the individual
was able to detect 40 counts per minute by direct frisk, which meets the
criteria for unconditional release. Because there were areas not accessible
to survey, the individual chose to be conservative and leave the radioactive
material stickers on the snubbers, and release them conditionally. The
snubbers were transported to Area 5 and installe( in their permanent location.
Area 5 has since been returned to its normal status as part of the RCA,
All survey conditions required by form RPF 02-515-2 were performed and
documented in a retrievable form on the Radiological Survey Map; however, not
using the correct conditional release was contrary to procedure RPP 02-515,
Revision 8 " Release of Material From the RCA." The release of equipment,
without using the proper form, increases the potential to lose accountability
and documentation of the equipment regarding destination, owner, Health
Physics requirements for the return of the item, and acknowledgment of the
item's return. Even though the decision to conditionally release these
snubbers was conservative, and not required, the correct form should have been
used. The correct f o rm, RPF 02-515-2, was completed upon identification of
the fact that the incorrect form was used.
Root Cause
The root cause for this incident was inadequate work practice, as evidenced by
the individual involved not follcwing procedural direction for conditionally
releasing equipment from the RCA. This was demonstrated when tha individual
l
_-_-__-_____ _ __ - _ - _ __
.
.,.,. .e- ~
,. - +
..
- . #
"
E.S Attcchment to'WO 97a0133 '
5-' Page 5 of 8 . ,
' '
6 *
f -
.
7 r
,y
- used an survey mapi tio'- document = tNa; radiological l conditions iof :the conditionally - .
- f
released equipment instead.of_the Conditional-Release Form RPF 02-515-2.5
.
7 g_c_ _
t
-
R.
,
correct mi ' steps Taken and Results Achieved:
4.. . - .
. _ . .
.
-The-
e -i A . fact .- finding -investigation ~ has been performed .: for , the '. event.
appropriate =. disciplinary actions _have been completed. ,
- : The Health Physics - technician responsible" for : the -incident _ was . counseled
that RPFr02-515-2- - is the correct form i to ur:e when - performing conditional?
-
release L of _- tools and equipment - f rom; the RCA," and was: required to-. fill. out -
the. correct form,
p
'
Corrective Steps'To Be Talen:
4 -
.
}Nofurthercorrectiveactions-arenecessary.- - .
L
j Date when Full compliance will se Achieved:
A
3ru11 Compliance was achieved on-October 24, 1997, when the-correct RPr.02-515-
12 form was completed. _At thatttime, the two snubbers ' (17994 and ' 20231)' were -
-
correctly econtrolled' _ and documented, as required by procec*ure RPP 02-515,
'
.
. Revision: 8; . " Release of Material from the RCA."
- -
,
.
1
"
s
.
1
k,
4
5
,-
.
'"
,.
_m
w
, - . . , a .- - -
<-
_ _
,.
'
.
Attechm:nt to WO 97-0133
.. Page 6 of 8
Violation 50-482/9720-03:
" Procedure RPP 02-215, ' Posting of Radiological Controlled Areas,'
Revision 11, Section 9.1.1 states, in part, ' Area Postings are shown
in Attachment A. ' Attachment A of the procedure requires that an area
be posted if contamination levels are equal to or greater than
1000 disintegrations per minute per 100 centimeters squared
(beta / gamma). S e ct f.on 9.1. 2 states, in part, ' Posted areas must be
clearly and conspicuously marked at all accessible sides and
entrances.'
Contrary to the above, on or about August 7, 1997, an area around the
spent fuel pool with contamination levels equal to or greater than
1000 disintegrations per minute per 100 centimeters squared
(beta / gamma) was not conspicuously marked on all accessible sides."
Reason for Violation:
On August 5, 1997, while performing an investigation survey for personnel who
had become contaminated while in the clean area around the work area, it was
noted by the contract Health Physics Technicians covering the work, that the
workers were grabbing the boundary rail as they used the ladder for access
into and out of the transfer canal. This had caused at least two personnel
contaminations to the " clean" area. This contamination has radiological
safety significance because the area around the Spent Fuel Pool is posted as a
Potential Hot Particle Area, with the pool itself being posted as a Hot
Particle Area.
To remedy the condition described above a herculite boundary was raised by
approximately one foot on the outside of the handrail. When the additional
herculite was installed, the strap, which is sewn to the permanent herculite
rail covers to allow for hanging a Health Physics posting, was covered over
af ter the posting was removed. After completing the addition of the extra
herculite the Health Physics ?ochnician(s) failed to re-hang the posting,
believing that the remaining postings round the area met the requirement for
" conspicuously marked."
On Thursday, August 14, 1997, Health Fhysics was notified by a resident NRC
inspector that the radiological postings around the Spent Fuel Pool on 2047'
elevation of the Fuel Building did not meet the " conspicuously marked"
requirements of RPP 02-215. His concern was that there was no Health Physics
posting for the Spent Fuel Pool area in a direct line of site as he enterec
the 2047' elevation of the fuel Building from the 2047' elevation of the
Auxiliary Building.
A proper posting was hanging approximately ten to twelve feet further down the
railing, and on each of the rail sections around the pool area. There is no
set maximum distance requirement for posting in the WCNOC Health Physics
procedures, and the " conspicuously marked" requirement is subjective. All the
hand rails which surround the Spent Fuel Pool area are also covered with
herculite covers, thereby forming a barricade around the area that prevents
inadvertent entry into the area.
During the planning phase of this job, the Site ALARA Committee determined the
need for an in-house Health Physics Nchnician to be assigned to this work to
promote better communications between the work groups and Health Physics, and
to ensure procedural compliance by the contract Health Physics Technicians
!
- - - - - _ _ - - _ _ _ _ - _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ - _ _
~ ,
+ , . - . - . - - - - - - . . - - . - - ~.. . -.- ~. . -
7"
"
/ ' Attec;un:nt - to Wo 9I-0133
r. 3Pagei7 of;8< s
s
.This: requirementL was noted in Attachment; 1, < Section : IV of the Pre-Job ALARA
~
Brief,Mbut was not: clearlyz.. stated. . Because : of the. _ unclear requirement L and ?
!
-Health: Physics-staffing-versusLwork load considerations, continuous 1coveragei
byL 11n-house technicians was - not - accomplished. - Multiple = in-house -. Health :
- Physics: Technicians were rotated through tne job'as their shift rotation and- -)
j
' other work ~ load-- allowed,--_- which . did not allow _ for as in-house Health Physics-
Technician to be:there every day.
. .
- ..
,
Minimal-'*in the field" support or. direction:.by- WCHOC Health . Physics ,
supervisj on was given - to the workers on this job. ;Although -Health Physics
supervisioni did attend ~ the - daily morning ' briefings that were heldPhysics in the- .
!
Health Physics /ALARA Briefing. Room at- Access : Control, Health
j
supervision was_ unable to monitor the- work in the _ field on a regular basis,
It was also noted at this time,' that-the Health Physics Supervisor Operations '
has 'a_ large administrative load,- which is directly related to the very large
supervisor . ratio, approximately 17:1,__ in the Health Physics
_
!
-worker to=
Operations groups ;
.
._ Root Cause
Root cause investigations revealed that Health Physics procedure RPP 02+215 is
u' individual interpretation in some areas _of posting.
vague and open -to _
requirements.-- The term " conspicuously marked" leaves the interpretation up to;
each individual.
Contributing Causes:
1. Due to Health Physics Technician staffing versus work load considerations,
Health Physics supervision changed a past practice, ar did not meet the ,
Site ALARA~ Committee requirement, by. not ' assigning a he.ise Health Physics l
Technician to continuously cover the work. [
2. Health Physics Supervision provided little "in the field" guidance or
monitoring of the work, leaving the contract workers to use their own
judgment. The administrative work load and the number of workers that the
Health Physics SO is directly responsible for, at least seventeen workers
on a routine basis, did not allow for the time "in the field" needed to
ensure work meets management expectations,
t ,
Corrective Steps Taken and Results Achieved:
p e On August 14, 1997, a Health Physics Technician was' dispatched to the area-
'
of concern. He placed a posting containing all required information in
,
direct line of- site from the door coming from the 2047' elevation-of the
Auxiliary- Building, and verified the remaining postings around the Spent ,
ruel Pool,
e: .On-' November 21,-1997, the Superintendent. of.-Radiation Protection issued - a
message 'to all Health Physics technicians and' supervisors, on management
'
expectations regarding the requirements of " conspicuously marked" posting.
,
' Corrective steps To Be'Takent ,
l .e- ' Health . Physics" Department will review the Health Physics procedures for
l = accuracy and usability. This review will be completed by March 31, 1998.
L I* Health Physics: management will evaluate:
1. The need for. dedicated personnel to perform procedure-reviews;.
-
!
l-
..-J . . , _ , . , _ . . . . . - , . . . . . _ , . ~ . . . . ,,,..m.- _ . . - -
p _...
.
.
- E Jj : lAttechmIntto_WOI9kOl33)
..j Pegai8 of 8:-
.2.-The use ofJcontract personnel without dedicated in-house'oversighti and,-
.
-3.' Actions necessary to ensure proper in-house Health Physics staffing.
~
- This evaluation will be completed by March 31,l1998.
- = Health Physics and Executive management - will'. evaluate responsibilities of
~ direct::line Health? Physics supervisors. . .This review -will . include
supervisory: time . spent "in the field"; organizational structure; .and' -
worker-to-supervisor ratios. -- This _ evaluation will be - completed by March
_
31,--1998..
Date When Full Compliance Will-Be Achievedt
- Full compliance was re-established on August 14, 1997, when a_-Health Physics
Technician,- who was - dispatched to the area of concern, placed a posting ;
containing allL required ..information in direct line of site with the - door
- coming = f rom , the 2047' elevation of the Auxiliary Building.- =This technician
also: verified the remaining postings around the Spent-ruel Pool.-
%
.
I
,
-!
I
4
-
J ~j
_
'.
i
!
4
t
_