ML20216G793

Responds to NRC Re Violations Noted in Insp Rept 50-482/98-09.Corrective Actions:Survey Was Performed of WCNOC Health Physics Calibration Lab Where Detector Had Been Stored

ML20216G793
Person / Time
Site:	Wolf Creek
Issue date:	04/10/1998
From:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-482-98-09, 50-482-98-9, WM-98-0034, WM-98-34, NUDOCS 9804200488
Download: ML20216G793 (4)

Text

4 W$LF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard President and Chief Executive Ofncer '

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April 10, 1998 WM 98-0034 U. S. Nuclear Regulatory Commission l ATTN: Document Control Desk 1

Mail Station P1-137 l Washington, D. C. 20555 l

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Reference:

Letter dated March 13, 1998, from Blaine Murray, NRC, to 0. L. Maynard, WCNOC l

Subject:

Docket No. 50-482: Response to Notice of l- Violatio 50-482/9809-03.

l l Gentlemen:

This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violation 50-482/9809-03. Violation 9809-03 identified

i. 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. Angus at extension 4077. I l

Very truly yours, I

_ Ofl}</W Otto L. Maynard OLM/rer ' '

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

/

7PI 9804200408 980410 PDR ADOCK 05000482 O ..

PDR

- :O'uO PO. Box 411/ Burlington, KS 66839 / Phone: (316) 3644831 An Equal Opportunity Employer MT!HcNET

Attachment I to WM 98-0034

.Page 1 of 3 violation 50-482/9809-03:

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" 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, February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e.4, recommends procedures for radiation surveys. f Procedure RPP 02-515, ' Release of Material From the,RCA,' Revision 9, Section 6.1, states, ' Thorough surveys must be performed to prevent the unconditional release of materials greater than the release criteria.'

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

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

Contrary to the above, proper surveys wore not performed to prevent the unconditional release of radioactive mat orials greater than the release criteria. Specifically, a remote monitor detector 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 I cm 2 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 l I

notified by Fermi plant personnel that one of the fifteen Science Applications  !

International Corporation (SAIC) Model PDE-4 remote communicating personal j electronic dosimeters borrowed by WCGS, and later returned to Fermi, was contaminated. This equipment had been released from the WCGS Radiologically I Controlled Area (RCA) on December 8, 1997 It was later determined that the l

actual contamination was restricted to one face of one of the extremity '

detectors attached to the PDE-4 dosimeter. The total activity, including both l loose and fixed contamination, was 1.42 x 10-4 micro-curies per gram. This l small amount of loose and fixed contamination was below that required for I l reporting, and the potential for a hazard to human health was minimal.

l 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 dosimeter. 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 WCCS RCA, along with fourteen other dosimeters, power packs, and extremity cables with extremity detectors and transmitters. One of the extremity detectors (serial number X3223) of dosimeter 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 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 detector #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, 1998.

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~ Attachment I to WM 98-0034 1

.Page 2 of 3 l

The technician who originally surveyed the contaminated detector at WCGS, and )

released it from the RCA, was interviewed to determine why the contamination l was not detected. Although it is documented that he released PDE-4 serial number RE1064, no documentation was found that showed the individual extremity j detector being released. Later discussions with the technician determined that i the extremity detectors 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 i decontamination to clean up the equipment. After decontamination, the

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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: I The rcot 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 i l detected the loose contamination. With multiple PDE-4 remote communicating I j personal dosimeters being surveyed, each with up to four extremity cables and detectors, the most probable cause for missing the contamination on extremity detector #XS223, was confusion as to which ext ren.it y 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.

i Information about the serial number of the instrument ano the isotopic content of the contamination was requested from Fermi.

I e 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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. Att'achment I to WM 98-0031

. . .Page 3 of 3 1

4) PIR 98-0504 was initiated to document and track investigations of the inci. dent. As a part of this investigation, it was determined that the incident was not reportable to the NRC 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 number of items he is working on during the release process.

Corrective Steps To Be Taken: i J

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

1998.

Date When Full Compliance Will Be Achieved:

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

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