ML20236A184
| ML20236A184 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/28/1989 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236A182 | List: |
| References | |
| WM-89-0070, WM-89-70, NUDOCS 8903160451 | |
| Download: ML20236A184 (5) | |
Text
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7 W$LF CREEK 1
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NUCLEAR OPERATING CORPORATION Baft D. Withers Presloont and Chief suecutive officer I
February 28, 1939 WH 89-0070 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, D. C. 20555
Reference:
Letter dated January 12, 1989 from L. J. Callan, NRC, to B. D. Withers, WCNOC Subj ect :
Docket No. 50-482: Response to Concerns Identified in Inspection Report 482/8832 Gentlemen Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response as requested in the Reference on the steps that WCNOC has taken and plans to
- ake to improve the performance in the areas of inattentiveness of health physics technicians and the apparent detioration in the effectiveness of health physics supervisory staff.
If you have any questions concerning this matter, please contact me or Mr. O. L.. Haynard of my staff.
Very truly yours, Bart D. Withers President and Chief Executive Officer BDW/j ad Attachment cc:
B. L. Bartlett (NRC), w/a E. J. H9ller (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a P.0 Box 411 i surlington, KS 66639 / Phone: Q16) 364 8831 An Equal OpportunHy Ernpioyer MS/He/ VET P
3903160451 890309 PDR ADOCK 0500 8,*,
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~,' Attachment to WM 89-0070
.,.Pasq 1 ef 5 i
concern' i
1.-
Insttentivenees of health physics technicians covering certain work activities in radiologically controlled areas.
a.
Several HP-technicians exhibited inattentiveness
'to work activities due to their preoccupation with nonjob-related reading materials inside containment and auxiliary building work areas.
b.
One HP technician was apparently almost asleep at a frisking station inside the auxiliary, building.
J c.
NRC inspectors noted that there was a rather relaxed atmosphere
-conc,er.ning t,he. gene.ral work activities kichin containment by the RP technicians assigned to the containment area.
2.
Apparent deterioration in the effectiveness of health physics supervisory staff.
i a.
A first line HP supervisor was observed being preoccupied with details of a crossword puzzle during working hours.
b.
The NRC inspectors noted that only a limited number of containment entries were made by assistant RP shift. supervisors.
c.
Radiological oversight of activities within the radweste building still needed improvement.
Response
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As a result of the 1987 Refueling Outage in which the NRC had criticized WCGS for lack of management / supervision involvement and oversight of work activities, some programmatic and management changes were initiated.
The changes resulted in management support of additional contract technicians during the 1988 refueling outage, more ef ficient planning of work activities to reduce exposure rates, initiation of an extensive review of health physics procedures and other enhancements to the Radiation Protection i
Program.
Additionally, management stressed to HP supervision the need to increase the observation of work activities in the Radiological Control
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Areas (RCA).
With the changes in HP management after the 1987 Refueling outage, corrective actions had been initiated to improve the Radiation Protection Progrem at WCCS.
These actions included a review of HP procedures,. review of the HP Technician Training Program, initiation of a Hot Particle Control Program.
and revisions to the Radiological Occurrence and Radiation Worker Violations and the Contamination Control Programs.
Regular meetings were initiated with HP Supervisors, Technicians, and deconners.
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. 'Attachsont to WH 89-0070
, Pega,2 of 5 In preparation for the 1988 Refueling Outage. HP management elected to use the same basic organizational approach as used in prior. refueling outages.
- However, two HP Supervisors were assigned (one on each shift) to assist in
]
HP operations, providing an HP shift supervisor and an assistant for each l
shift.
This approach in conjunction with a significantly greater number of I
work activities and contract technicians did not provide the efficient
{
oversight and direction of the technicians that was expected.
The HP Supervisors who were assigned additional responsibilities to cover HP operations aspects of the refueling outage still had to maintain their
)
normal day-to-day functions and responsibilities.
A review of total HP ll I
supervision entries in the RCA and containment identified an increase in field activities by HP supervisors over previous outages.
It has been a past practice at WCCS to encourage technicians and supervisors to take work and lunch breaks in the office area near the Primary Access Control.
This practice was encouraged to facilitate easy access for work activity coverage and to respond to changing radiological working conditions. This practice can easily lead to a perception of a more relaxed atmosphore.
Wolf Creek Nuclear Operating Corporation (WCNOC),has taken or plans to take the following steps to improve the Radiological Protection Program 1.
A policy has been implemented in which nonjob-related reading material f/
d is not allowed inside the RCA.
Appropriate actions are taken for v
f#s RN individuals violating this policy.
In early December 1988, a contract 5
technician was dismissed after being observed reading nonj ob-related material inside the RCA. Prior to the next refueling outage, a station distribution letter will be distributed to plant personnel reiterating this policy.
2.
An evaluation of the HP Supervisor / Technician office area at the Access Control Point has been conducted.
The evaluation considered separate of fices for HP Supervisors and Technicians and a specific break area for nonjob-related activities.
Recommended changes will be completed as appropriate prior to the next refueling outage.
3.
As part of the refueling outage criti ue, WCNOC is evaluating different t
organizational approaches for future refueling outages.
One approach being considered is maintaining existing responsibilities of the HP Supervisors and assigning senior HP technicians as Leads to assist the HP Supervisor-Operations. This approach would onsbie the assigned Leads to direct their attention to HP operational activities, ensuring that proper attention is provided to work activities and radiological program practicos.
This evaluation and subsequent changes as appropriate will be completed prior to the next refueling outage.
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. Attachment to WM 89-0070
- .' ' Paga 3 cf 5 1
4.
The Health Physica group will enhance employee awareness of the Radiation Protection Program by revising the monthly reports issued to plant Supervisors to include items such as personnel contamination incidents, radiological occurrences and radiation worker violations.
Additionally, a Radiation Protection Hanager Newsletter will be made available to radiation workers to increase personnel awareness of Radiation Protection activities, problems and improvements.
As is true with any major program, changes are gradual and must be implemented systematically and orderly to avoid undesirable perturbations.
r This is especially true with the Radiological Protection Program because it affects all employees and.must have the input and cooperation of all
- managers, supervisors and employees.
Even with ' careful implementation, program changes may uncover additional areas of weakness that need correcting or improving.
We feel that as we are making changes at WCGS, weaknesses that are uncovered may be perceived, in some cases, as deterioration of effectiveness.
For
- oxseple, the NRC inspection of November 1988, was conducted during the Refueling III outage.
It should be noted that this outage included more work activities (many of them happening simultaneously) such as Steam Cenerator testing.. fuel rod and control rod testing and modification, etc.,
than any previous outage.
The Radiation Protection Manager has conducted extensive discussions on the Refueling III outage activities with about fourteen Health Physics contractors and WCGS personnel. The following areas show definite improvement over previous outages:
1.
Cavity Decontamination and Work in the Cavity-The HP group devised a plan for cavity decontamination and work in the cavity which was fully supported by Plant Management and the Supervisors of other departments, especially Planning and Scheduling.
An area of weakness discovered in the cavity decontamination as well as some of l
the steam generator work, was the HP shift turnover, primarily on l
weekends.
This area is being addressed by a total revision of the 4
i procedure that addresses HP Shift Logs and Shift Turnover, and by evaluation of the HP organization for future outages as previously noted.
Planning and Scheduling asssigned 2.
Containment Coordinators Containment Coordinators to coordinate the work in containment.
In past refueling outages other groups had depended on Health Physics to help coordinate jobs. The new Containment Coordinators freed the Health Physics containment coordinator (HP Containment Shift Tech) to concentrate on radiological controls.
3.
Plant Management allowod a significant increaso in the tiene for Reactor Coolant System cleanup, thus reducing exposure for radiation workers performing activities near primary coolant system Component 4.
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DAttcch: nt to WM 89-0070 4
.Pcg3 4 cf 5 4.
Restricting access to the containment bioshield for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the hydrogen peroxide addition event was requested by Health Physics and approved by Plant Management.
5.
The necessity for flushing the steam generator primary bowl drain valves was recognized by. Outage Management, and was factored into.
the schedule with contingency plan for removal / replacement of BBV0265 should flushing attempts prove inef fective.
6.
Adequate sock-up training for the steam generator nossle dem installation and removal activities was provided by Management.
7.
The steam generator rotation for sludge lance /FOSAR activities was revised to eliminate additional work atea set-up and tear-down requirements, at the request of Health Physics ALARA.
8.
The preliminary schedule was revised to allow completion of Reactor Coolant Pump seal work prior to draining the secondary aide water (shielding), at the request of Health Physics ALARA.
9.
During the initial head lift evolution, the evacuation of all non-
-essential personnel from the Containment Building was requested by Health Physics and approved by Plant Management.
- 10. Excessive exposure rates (12-15 R/hr) were identified during the initial access to the reactor cavity transfer tube blind flange area f or the perf ormance of Local Leak Rate Testing activities.
The Containment Coordinator was responsible for the implementation of effective shielding (water) in the transfer pit, thereby lowering exposure levels to 50 mR/hr.
- 11. Management recognised the exposure hazards associated with the I
" unplanned" repair of primary steam generator manway bolt holes and requested Health Physics assistance in temporary shielding design applications.
12.
Because of the job exposure and difficulty associated with certain pipe weld examinations, substitute exam locations were elected without any prior prompting from Health Physics ALARA.
- 13. During the second reactor cavity draindown for steam generator nozzle dam removal and manway installation, the transfer of the reactor head to the upper cavity (shielding for upper internals package) was not performed.
This was considered ALARA due to the Outage Management commitment of restricting access to the 2047"/2068" einvations surrounding the butiding refueling cavity.
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.g.
,httachment to WM 89-0070 g.,P:ga,5 cf 5
- 14. Toc initial plan for replacement of dislodged specimen capsula plugs required personnel access to the reactor vessel flange during cavity
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draindown and with the upper internals removed.
Due to the h!.gh l
exposure aspect of-this activity, effective mock-up training was provided at the request of departmental supervision.
- 15. There were several work activities performed this outage that demonstrated successful inclusion of the ALARA program and concepts.
All of these activities were fully supported by Plant Management.
16.
Personnel Contamination Control and Documentation - Proccdures have been revised and created since the last outage to address hot particle contamination and to improve control and documentation of personnel contamination incidents, in general. Procedure HPR 03-015 was revised prior to the outage.
As weaknesses were uncovered during the outage the procedure was revised again to include more detail on decontamination and documentation.
Another revision was-made toward the end of the outage to provide better control and documentation instruction on Form HPH-03,015A.
II. Handling of Radiation Work Permits (RWPs) - Initiation and approval handled primarily by one Senior HP Technician.
This of RWPs was ensured that RWPs were printed out and properly approved in time to avoid any delays on the respective jobs.
Because of the number of
- 18. Quality of Radiological Surveys experienced, conscientious contract techs, the majoritt of routine and non-routine surveys were very thorough and very well documented.
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