ML20198N833
| ML20198N833 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/31/1997 |
| From: | Warren C WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-97-14, WO-97-0120, WO-97-120, NUDOCS 9711060131 | |
| Download: ML20198N833 (7) | |
Text
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W@ NUCLEAR OPERATING CO LF CREEK r
ci.y c. warren Chef Operating Oftter WO 97-0120 October 31, 1997 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter dated October 2, 1.i97, from T. P. Gwynn, NRC,-to 0.
L. Maynard, WCNOC
Subject:
Docket No. 50-482:
Response to Notice of Violations 50-482/9714-01, 9714-03, and 9714-05 Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violations 50-402/9714-01, 9714-03, and 9714-05.
Notice of Violation 9714-01 cites ineffective maintenance of a procedure to support implementation of Technical Specification Amendment 10P.
Notice of Violation 9714-03 cites an example of a radiation worker failing to have the correct dosimetry required by the Radiation Work Permit.. Notice of Violation-9714-05 addresses a failure to perform surveys of radiation levels in untentricted and controlled areas.
WCNOC's response to these violations is provided in the attachment.
If you have any questions regarding this response, please contact r,e at (316) 364-8831, extension 4000, or Mr. Richard D.
Flannigan at extention 4500.
Very truly y rs,
' b C1 C. Warren CCW/jed Attachment cct W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a
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Attachment to WO 97-0120 Page 1 of 6 Violation 50-482/9714-01:
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" Technical Specification 6.8.1.a
- requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures r ecorJDended in Appendix A of Regulatory Gui 1.33, Revisior 2, February 1978.
Regulatory Guide 1.33, Revision 2,
February
- 1978, Section 3.f.,
recommends, in part, that procedures be established for the operation of containment.
Surveillance Procedure STS GP-007, "CTMT Penetration Isolation Verification,"
has been established in accordance with these requirements.
Contrary to the above, on August 20, 1997, Procedure STS GP-007, "CTMT Penetration 1 solation Verification," was not effectively maintained in that the licensee implemented Technical Specification Amendment 100, which relocated a list of containment isolation valves from Technical Specification 3.6.3 to Procedure STS GP-007, without providing adequate guidance for how this procedure would subsequently be used to identify containment isolation valves covered by Technical Specification Limiting Condition for Operation 3.6.3."
Reason for Violation:
The implementation of Technical Specification (T/S) Amendment 108 on August 19, 1997, resulted in the inability of the Control Room personnel to properly implement Technical Specification (T/S) 3.6.3).
On August 28,
- 1997, Centrol Room personnel became concerned with the operability of valve BM "V-36 during the performance of procedure STS IC-616B, "SLV RLT TST K616 Safety Injection."
This valve was identified in the Equipment Out of Service Log as a T/S 4.0.5 failure.
The Shift Supervisor (SS) reviewed the applicable system drawings, T/S Amendment 108, and the physical location of the valve (the first valve inside containment) and conservatively determined that valve BM HV-36 was a containment isolation valve. The SS instructed the valve be closed and tagged with Clearance Order 97-1047-BM until additiona.1 reviews could be completed on day shift.
Day shift personnel subsequently reviewed Updated Safety Analysis Report Figure 6.2.4-1, and determined that valve BM HV-36 was not a containment isolation valve.
Day shift personnel then removed Clearance Order 97-1047-BM.
Due to Control Room personnel questions and concerns with compliance to T/S
- 3. 6. 3, Operations management decided that STS GP-007, "CTMT Penetration Isolation Verification," was the governing procedurc for implementation of T/S Amendment 108.
This decision process occurred after T/S Amendment 108 was released for implementation.
The cause of this event is inadequate change management of program implementation.
Evaluation of this event disclosed examples of ineffective planning, communication, ownership, and implementation.
Attachment to WO 97-0120 Page 2 of 6 Corrective Steps Taken and Results Achieved 1 Procedure STS GP-007, "CTMT Ponecration Isolation Verification," was twvised October 4,
1997, to clearly specify which valves are containment isolation valves.
Operations management has provided guidance to operating crews concerning the effects of Amendment 108 on containment isolation valves.
Corrective Steps That Will De_ Takent Licensing will coordinat, meetings to discuss the current license amendment requests which have been submitted, but not approved, as well as license amendment requests currently in process.
These meetings will assure that appropriate ownership of each amendment and that implementation activities have been considered prior to receipt and implementation of the amendments.
This is an interim measure to ensure amendments are properly implemented which will be effective until the procedure revision described below is completed.
In addition, Procedure AP 26B-001, "P,evisions to the Operating 1.icense and/or Technical, Specifications," will be revised to ensure the following actions occur'
- 1. Amendment ownership is established
- 2. Pre-submittal meetings are held to discuss amendment implementation
- 3. Ownership is established for implementotion activities 4.
Post amendment receipt meetings are conducted to review pre-submittal decisions and onsuro Wolf Creek is prepared to implement the amendment.
This revision will be completeu by January 31, 1998.
Data When Full Compliance Will Be Achieved:
WCNOC is currently in tull compliance.
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Atta hment to Wo 97-0120 Page 3 of 6 d
Violation 50-402/9714-03:
"10 CFR 20.1302 (a) requires, in part, that the licensee make or cause to be made, surveys of radiation levels in unrestricted and controlled areas to demonstrate complitnce with the dose limits for individual members of the public in paragraph 20.1301.
Contrery to the above, on Septenber 16, 1997, the licensee moved a spent resin liner without first performing a survey of the radiation levels in the unrestricted area adjacent to the restricted area south of the radwaste building.
A subsequent evaluation estimated the dose rate in the unrestricted area well in excess of the limit of 10 CFR 20.1301."
Reason for Violation Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of 10 CFR 20.1301 and 10 CFR 20.1302 occurred.
- However, a-subsequent evaluation has shown that the dose rates identified in 10 CFR 20.1301 were not exceeded at the unrestricted area boundary.
This clarification is necessary because a clear understanding of the location of the unrestricted boundary and the radiological controlled area (RCA) boundary was not adequately communicated to the inspector. NRC Inspection Report 97-14 and Notice of Violation 9714-03 reflect this misunderstanding.
Health Physics personnel communicated clarifying information to the NRC Senior Resident Inspector on October 8, 1997.
This event involved the transfer of a High Integrity Container (HIC) from a process shield to a shielded transport cask on September 16, 1997 During the transfer process the HIC was removed from one shielded area and transferred to another shielded area.
It was during this evolution that the radiation levels increased in tne RCA because the HIC was not shielded during the transfer process.
For this evolution one Health Physics employee was placed at the southeast and southwest corners of the RCA to monitor the radiological conditions and hc4t any traffic along the access road adjacent to the south side of the Radwaste Building during the HIC movement evolution.
Each Heal"h Physics employee carried a survey meter and was qualified to operate the survey meter.
However, since they were not Health Physics Technicians, they could use the survey meters for personal information only and were not allowed to perform surveys.
The radiaticn levels observed where the personnel were stationed was 1.5 mrem /hr.
This was below the 2 mrem /hr. limit specified by 10 CFR 20.1301 and 20.1302.
The Health Physics employees halted one Security officer on foot, two Security of.ficers on bicycles and one truck during the approximately
-fifteen minute evolution.
10 CFR 20.1301 specifies that, "The total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem in a year," and "The dose in any unrestricte d area from external sources does not exceed 0.002 rem in any one hour."
Compliance with the dose limits. are specified by 10 CFR 20.1302 (a ) as, "The licensee shall make or cause to be made, as appropriate, surveys of radiation levels to unrestricted and controlled areas...to demonstrate compliance with the dose limits for individual members of the public in P0.1301."
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Attachtnent t o Wo 97-0120 Page 4 of 6 l
Procedure AP 25A-001, " Radiation Protection Manual," step 4.34, defines the restricted area as bounded by the Security fence (protected area boundary).
The calculation for the RCA boundary dose rate previously provided to the resident inspector was understood by the NRC Resident inspector as the unrestricted area boundar y Joss rate.
A new calculation was performed using the protected area fC.ve.4s the unrestricted area boundary and the result was 1.5 mrem /hr or 0.38 mrem for the 15 minute evolution.
The new calculations demenstrate the unrestricted area boundary was maintained below the limits specified by 10 CFR 20.1301 and 1302, however, there were no surveys to demonstrate ccmpliance as required by 10 CFR 20.1302 (a).
AP 25A-200, " Access to Locked High or Very High Radiation Areas," step 4.3 defines a transient locked high radiation area as transfer of items that are
> 1 rem /hr at 12".
These areas will not be posted during transfer as long as a Health Physics Technician is in direct surveillance of the areat step 6. 6 discusses transient or temporary locked high radiation areas not controlled by red flashing lights or keys.
These areas shall have continuous direct surveillance to prevent unauthorized entry.
The cause of this event is lack of procedural guidance to perform surveys in the unrestricted areas for the purpose of monitoring ionizing radiation in excess of 10 CFR 20 limits.
Corrective Steps Taken and Results Achieved:
Performance Improvemera Request (PIR) 97-2839 was initiated to address this issue.
Corrective Actions initiated to address P1R 97-2839 include the performance of a review of 10 CFR 20 and a comparison to existing procedures to determine any additional areas of missed guidance.
This review was completed on October 14, 1997 No areas of missed guidance were found.
As an interim measure, until procedure RPP 02-210, " Radiation Survey Methods,"
is revised, Health Physics personnel will conduct the following activities when moving H1Cs
- Access to effected areas within the restricted area will be controlled and surveys will be performed.
Surveys of the unrestricted area will be performed and access will be restricted to those areas when radiation levels exceed 10 CFR 20 limits.
RWP 970019 pro-job checklist has been revised to caution individuals to survey unrestricted areas if dose rates are exceeded at the RCA boundary.
Corrective Steps That Will Be Takent Procedure RPP 02-210, will be revised to incorporate guidance on surveys of unrestricted areas.
Date When Full Compliance Will Be Achieved:
WCNOC is currently in full compliance.
The procedure revision for these changes will be complete by January 30, 1998.
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Attechment to UO 97-0120 Page 5 of 6 Violation 50-402/9714-05:
" Technical Specification 6.11 requires, in part, that radiation workers adhere to procedures for personnel radiation protection consistent with the requirements of 10 CFR Part 20.
Administrative Procedure AP 25B-100,
' Radiation Worker Guidelines,'
Revision 4,
Section 6. 3. 6, states that ' Individuals shall comply with the RWP [ Radiation Work Permit) requirement.'
Contrary to the above, on August 28, 1997, a worker entered the radiologically controlled area without the electronic dosimetry required by Radiation Work Permit 970009."
Reason for Violaticn On August 20, 1997, an individual arrived at Access Control to enter the RCA for a tour of the pump and tank rooms on the 1974' elevation of the Auxiliary Building.
Upon arrival, he found the area around the book containing copies of the Radiation Work Permits (RWP) to be congested.
After signing into the Radiological Controlled Area (RCA) through the Automated Radiological Access Control System the individual was able to access the RWP book and review RWl: 970009.
Upon completion of the review, the individual performed a cursory check for proper dosimetry. The individual proceeded towards the RCA boundary.
During this time the individual was engaged in an on and off conversation, which distracted the individual from the sign-in proce.s.
After accessing the pump and tank rooms, the individual was in transit to the "B"
Centrifugal Charging Pump room, the individual neticed that the electronic dosimeter (PD-1) was not in place.
The individual insediately exited the area, along with another radiation worker who had been with the individual, and notified the Health Physics Shift Technician.
The PD-1 was located in the rack of the computer station where the individual had signed into the RCA.
Based on the other radiation worker's PD-1, who had been with the individual the entire time, the individual was assigned a dore of zero mrem.
The causs of this event was the inattention to detail caused by distractions during the RCA sign-in process.
A contributing factor wao the lack of a strong continuing training program for all radiation workers.
Corrective Steps Taken and Results Achieved:
The worker notified the Health Physics Shift Technician immediately upon discovering the dosimetry discrepancies.
This resulted in a potential reduction of exposure, and allowed Health Physic; personnel to evaluate and perform corrective action in a more timely manner.
Dose calculations were performed for the worker.
No exposure resulted from the incident.
This is a short term action that will be implemented until further evaluation can be performed.
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, *. e Attachment to WO 97-0120 Page 6 of 6 e
"Just-In-Time" train.ng has been conducted to reinforce Radiation Protection policies and supplement radiation worker training.
This training included a practical factors qualification for radiation workers to demonstrate the correct
- login, dress out, undress and RCA exit procedures.
- The Manager Radiation Protection has given direction for Health Physics personnel to question radiation workers on expected standards.
The Health Physics Access Control area has been declared a *!Jo Talk Zone" to minimize distraction of radiation workers entering the RCA.
In addition a Security officer has been assigned to the Health Physics Access Control to verify radiation workers entering the RCA are wearing proper dosimetry.
Corrective Steps To Be Taken In an effort to improve human performance in the Access Control area, WCNOC Health Physics personnel will submit a proposed facility change to be evaluated using the design change process.
This proposal will be submitted by January 1, 1998.
Date When Pull Compliance Will Be Achieved:
WCt10C is currently in full compliance.
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