ML20217N836
| ML20217N836 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/28/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-11, WM-98-0038, WM-98-38, NUDOCS 9805050450 | |
| Download: ML20217N836 (3) | |
Text
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4 WQiF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard President and Chief Executive Officer I
i April 28, 1998 WM 98-0031 4
U. S. Nuclear Regulatory Commission ATTN Document Control Desk i
. Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter' dated April 2, 19'38, from Blaine Murray, NRC, to 0.
L. Maynard, WCNOC
Subject:
Docket No '50-482:
Response to' Notice of Violation 50-182/9811-01.
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3entlemen:
i This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violation 50-482/9811-01.
Violation 9811-01 identified a failure to label radioactive material containers.
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,
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extension 4000, or Mr. Michael J. Angus at extension 4077.
Very_truly you.4
/
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fi.
ll/Y ^m Otto L. 6 aynard OLM/rir 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 t
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h 9805050450 980428 g (, OI PDR ADOCK 05000482 y
G PDR P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportundy Employer M F'HCVET J
Attachment'I to WM 98-0038
'Page 1 of 2 p
Violation 50-482/9811-01:
1 "10 CFR 20.1904 (a) requires that the licensee ensure that each container of - licensed material bears a durable, clearly visible label bearing the radiation symbol and the words, ' CAUTION RADIOACTIVE MATERIAL' or DANGER PADIOACTIVE MATERI AL. '
The label must also provide sufficient 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 exposures.
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 labeled.
l 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 vehicle.
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 dose rates just slightly greater than background readings.
The vehicle was staged for the receipt of the incoming material adjacent to the radwaste storage building.
It_was determined that the first box unloaded was the source of the elevated dose rates on the trailer.
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 technician.
The dose rates on the trash bags were less than 2mr/hr.
After security inspected the bags, they were piled within direct sight of the attending technician but outside of the direct work area.
Later, the technician directed the Deconners to take the bags and place them with the other waste bags.
The last bag unloaded from the container was a magenta laundry bag.
The bag was labeled with red duct tape and contained the following: dose rate, date and surveyor's initials when generated during our refueling outage.
The bag was taken directly to the west side of the building, which was unoccupied at the time.
Contact dose rate on the magenta bag was 30mR/hr and 8mR/hr. at 12 inches.
The yellow trash bags _ and the magenta laundry bag did not have a label indicating " Caution Radioactive Material."
The technicians checked the posting of the radwaste storage building.
The building was a posted Radiation Area and a Radioactive Materials Area.
The technicians were comfortable knowing the radiological hazards (dose rates) of the material were identified.
They were knowledgeable that the material was stored / staged in a properly posted area.
The yellow and magenta colors on 3
the bags identified the material as radioactive material.
4 After the receipt and the subsequent shipping evolution, the Health Physics technicians did not return to the area to relocate or label the bags.
The l
magenta laundry 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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- gAttachmentlI toiWM 98-0038
- v. v
- E Page.2;off2.
L, Root Cause:
The', root cause7 of thisy violation Lis personnel-error - because of-~ wrong.
assumptions. made by. Health. Physics technicians.
WCNOC's 1 investigation revealed:that no' willful; procedure violation occurred; however, personnel did -
not..: realize :that' the procedure requirements-applied-to this specific
. s it ua t ion'.
The technicians assumed that:since the area was properly posted in-
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accordance ' with ' Procedure RPP.02-215, " Posting of Radiological' Controlled -
. Areas," the' bags themselves did not require additional labeling..This mindset.
was the major; contributor. to the personnel error.
The technicians. believed
.that' labeling of:the bags would:have been redundant.becauseithey werefbeing
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placed.in t.he posted area.
Contributing Cause:
Confusion existed in the definition of,." container,"'with regard to bags used
- within the~ radiologically. controlled area to transport and store -radioactive
. material.
Procedure R?P 02-215 does not provide. clear guidance in this area.
Corrective Steps Taken and Resulta Achievedt Upon notification byLthe'NRC Resident Inspector on March 19, 1998, the seven L
bags were. properly labeled.
Perfo'rmance Improvement Request '( PIR) 97-0791' was initiated.to evaluate.this, event and-to' develop a' corrective. action plan.
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- ' The Superintendenu Radiation 1 Protection issued letter HP 98-004, " Interim i
Corrective Action PIR 98-0791," on April 8,
1998,' to all Health Physics
-personnel to p? ovide interim guidance on ' radioactive material container-j labeling.
Thi' letter stated that all bags containing radioactive material Ei shall be treatadLas a radioactive material. container.
The individuals involved -were counseled on the importance of procedure reviews prior'.to beginning'a job evolution.
Corrective Steps To Be Taken
. Procedure RPP 02-215 will be revised to provide guidance that bags are to be j
considered radiological material containers and labeled accordingly.
This li action will be complete by June 1, 1998.
The Health > Physics technician continuing training cycle will. include testing-on procedures to ensure. a clear understanding of procedures and their intent. This action will be complete by August 6, 1998.
Date When Full-Compliance Will Be Achieved Full' compliance was ' achieved on March 19, 1998, when the seven bags' were properly labeled as radioactive material containers.
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