ML20247H749
| ML20247H749 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/22/1989 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NO-89-0098, NO-89-98, NUDOCS 8905310311 | |
| Download: ML20247H749 (7) | |
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W41.F CREEK 4
NUCLEAR OPERATING CORPORATION John A. Seney vice Precedent Nucieer Operations f-May 22,1989 NO 89-0098
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U. S. Nuclear Regulatory Cmmission A'I'IN: Docurrant Control Desk Mail Station P1-137 Washington, D. C. 20555 Reference Ietter dated April 21, 1989 from L. J. Callan, NRC, to B. D. Withers, NCNOC
Subject:
Docke No..50-482: Response to Violation 482/8909-01, 02, and 03 Gentlenen:
1 Attached is Wolf Creek Nuclear Operating Corporation's (NCNOC) responde.to
' violations 482/8909-01,.02, and 03 which were documented in the Reference.
Violation 482/8909-01 involved the failure to perform exit whole body counts, 482/8909-02 involved the ovw. w sure of the skin of the whole body, and 482/8909-03 involved the failure to cmplete Technical Specification surveillance test.
If you have any questions concerning this matter, please contact ne or Mr. O. L. Maynard of my staff.
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i Very truly yours, NC 4A John A. Bailey -
Vice President L
Nuclear Operations l
JAB /jad Attachment j
cc:
B. L. Bartlett (NRC), w/a i
E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a l
D. V. Pickett (NRC), w/a 8905310311 890522 PDR ADOCK 05000482 N4 i
Q PDC P.o. Box 411/ Burfington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunny Ernpioyer MT/HC/ VET l
Attachment to NO 89-0098 Page 1 of 5 i
Violation (482/8909-01): Failure to Perform Exit Whole Body Counts
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Finding:
TS 6.11 requires that,
" Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be I
approved, maintained, and adhered to for all operations involving personnel radiation exposures."
Administrative Procedure ADM 03-100,
" Health Physics Dosimetry Program."
Revision 6, dated October 27, 1987, paragraph 4.1.3.1 requires that, individuals who have been issued a thermoluminescent dosimeter will receive a termination whole body count.
If an individual terminates without obtaining an exit whole body count, an attempt will be made to contact the individual to request they return to WCGS or another mutually acceptable facility for a whole body count.
A record indicating the attempted contact i
will be placed in the individuals exposure history file.
Contrary to the above, the NRC inspector determined on March 14, 1989, that during the period July 1, 1988, through March 14, 198.',
seven individuals had left the WCGS without receiving an exit whole body count and no record was included in their individual exposure history file indicating that an attempt had been made to contact the individual to request they return to WCGS or another mutually acceptable facility for a whole body count.
Reason For Violation:
The failure to include a record of attempted contact for a whole body count for individuals leaving Velf Creek is attributed to non-licensed utility personnel error in failing to follow the procedural requirements of ADM 03-
- 100,
" Health Physics Dosimetry Program" and HPH 01-019,
" Exposure History Files".
Corrective Steps Which Have Been Taken And Results Achieved:
On March 22, 1989, Health Physics personnel initiated a review of Exposure 5'istory Files for individuals leaving Wolf Creek Generating Station (WCGS) during the period July 1, 1988 through March 15, 1989.
This review consisted of 761 Exposure History Files, of which an additional 3 individuals were identified who had left WCGS without receiving an exit whole body count and there was no letter in their individual Exposure History File requesting that they return to WCGS or another mutually acceptable facility for a whole body count. Form HPH 01-019-G, " Request For Exit Whole Body Count" was initiated for those individuals in which no l
record of attempted contact had been included in the individual's Exposure History File.
These forms have been transmitted to the QA Record Room to be included in the individual's Exposure History File.
Attachment to NO 89-0098 Page 2 of 5 Corrective Steps Which Will Be Taken To Avoid Further Violations:
Health Physics supervision has provided additional instructions to those personnel responsible for the Exposure History Files on the procedural requirements to include Form HPH 01-019-G as part of the Exposure History File.
Procedure HPH 01-019 is currently under revision to clarify the requirement for Form HPH 01-019-G to be included in the Exposure History File as a QA record..
This procedure revision will be included in the Health Physics required reading for those personnel responsible for the Exposure History Files to assure familiarity with the procedure and to reemphasize the requirement for Form HPH 01-019-G to be included in the Exposure History File.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by June 30, 1989.
l Violation (482/8909-02):
Overexposure to the Skin of the Whole Body Finding:
10 CFR Part 20.101(a) requires, in part, that "
no licensee shall
- possess, use, or transfer licensed materials in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess of.
(7.5 rems per calendar quarter to the skin of the whole body)."
Contrary to the above, the NRC inspector determined during a review of Licensee Event Report 88-028, dated January 6, 1989, and subsequent onsite inspection on March 15, 1989, that an individual had received a radiation exposure to the skin of the whole body of 12.5 rems on December 9, 1988, from a hot particle located on the individual's chin.
Reason For Violation:
On December 9, 1988, at 1750 CST, an individual in the Radiologically Controlled Area (RCA) was discovered to have a localized area of facial contamination.
Health Physics personnel subsequently removed a 0.7093 microcurie (uci) Cobalt-60 particle from his chin.
The individual had been working in the area of the polar crane inside the containmen. building.
i lc s
l Attachment to NO 89-0098 Page 3 of 5 An investigation concluded that it was likely that the individual had become contaminated when he deposited his tools just prior to exiting containment.
- However, because this conclusion could not be positively verified, it was conservatively assumed that the contamination had occurred at approximately 1334 CST, upon initiation of the work activities.
Therefore, in determining the skin dose to the individual using the computer code VARSKIN, the maximum exposure time was 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 16 minutes.
With this exposure time, the official dose assigned to this individual due to this incident is 12.5 rem j
to the skin of the whole body.
This dose exceeds the 10 CFR 20.101 permissible occupational dose of 7.5 rem per quarter to the skin of the whole body.
j Corrective Steps Which Have Been Taken And Results Achieved Following discovery of the hot particle on December 9, 1988, work was suspended in the area of the polar crane.
Health Physics personnel performed surveys for hot particles in the area in which the individual had been working and on tools and equipment that had been used.
These surveys i
no additional hot were completed at approximately 2200 CST and identified particles or unexpected gross contamination.
Following completion of these
- surveys, the work activities were resumed, with Health Physics personnel performing more frequent monitoring.
The individual and his co-workers were interviewed in an attempt to identify the most likely time and location at which the hot particle had been picked up.
Based on the information obtained, it was determined that the work had involved some crawling around due to tight work space and some repositioning of tools.
Further hot particle surveys, with particular emphasis on the areas in which the individual had most likely picked up the hot particle, were conducted on the morning of December 10, 1988.
During these surveys one additional hot particle was found in the area in which the workers temporarily stored their tools.
This second hot particle was composed of 0.00128 uCi of Cobalt-58 and 0.0316 uCi of Cobalt-60.
In an effort to identify the source of the hot particles detected in the i
polar crane area, the relative abundance of Cobalt-58 and Cobalt-60 of the particles was compared to the relatise abundance of these isotopes detected in recent sample analyses.
From data comparisons, it was determined that these particular particles had not originated from current refueling l
activities, but had most likely been created during prior refueling
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activities.
Corrective Steps Which Will Be Taken To Avoid Further Violations _:
Following this incident, previously performed radiological surveys of the area involved were reviewed for indications of abnormal contamination.
This review verified that there had been no previously identified hot particles in the area.
No unusual radiation levels or evidence of abnormal l
contamination had been detected in the polar crane area.
In conjunction with this effort, records of previous incidences of personnel contamination during the current refueling outage were reviewed for similarities to the incident discussed in the Licensee Event Report.
No similarities to this event were identified.
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t Attachment to NO 89-0098 Page 4 of 5 Based on the evaluations performed, it has been concluded that this is an isolated incident.
An internal review of the Hot Particle Contamination Control program has been performed, and the program was determined to adequately address Hot Particic concerns. Consequently, no changes to this program are considered necessary at this time.
Date When Full Compliance Will Be Achieved i
Full compliance has been achieved.
Violation (482/8909-03):
Failure to Complete Technical Specification Surveillance Test Finding:
TS 3/4.3.3.10 Table 4.3-8 and TS 3/4.3.3.11, Table 4.3-9 require that process effluent radioactivity monitors, which provide an alarm and automatic termination of effluent releases, be source checked prior to each release.
The licensee's system operating procedures for performing radioactive effluent discharges require that this source check surveillance test be performed and documented in accordance with STS SP-001,
" Process Radiation Monitoring System Source Check and Valve Stroke," prior to each effluent batch release.
Contrary to the above, the NRC inspector determined on March 15, 1989, that only 25 out of 203 liquid effluent batch releases, one containment purge release out of 51 containment releases, and none of the seven gas decay tank releases conducted in 1988 had completed STS SP-001 surveillance test results in the WCGS records vault documenting the performance of the process radiation monitoring system source check and valve stroke surveillance test prior to each radioactive effluent batch release.
Reason For Violation:
The reason for the violation was the failure of Operations personnel to properly document the performance of the process radiation monitoring system source check and valve stroke surveillance test prior to each radioactive effluent batch release.
Various methods for documenting the performance of the source check were utilized such as Control Room logs or the surveillance test procedure.
WCNOC is confident that the appropriate source checks and valve stroke tests were being performed prior to each radioactive release, however proper documentation was not utilized.
Attachment to NO 89-0098 Page 5 of 5
_ Corrective Steps Which Have Been Taken And Results Achieved:
On March 20,
- 1989, Operations Management issued a letter to licensed operators explicitly requiring the use of STS SP-001 for documenting the performance of the source check and valve stroke test (when required) prior to each radioactive effluent batch release.
In addition, the WCOS Release Permits utilized in procedure ADM 04-023
" Radioactive Releases" were revised on March 28, 1989 for Operations personnel verification of the process monitoring system source check, valve stroke test (when required) and release setpoints prior to a radioactive release.
Corrective Steps Which Wil Be Taken To Avoid Further Violations:
The system procedures (SYS GT-120, SYS HA-204, SYS HB-125 and SYS HF-200) utilized in aligning the system for a radioactive release contain the requirements to perform the applicable section of STS SP-001 prior to each planned radioactive release.
These procedural controls in addition to the corrective steps taken above should prevent further violations.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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