ML20248L586
| ML20248L586 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/05/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-10, WM-98-0049, WM-98-49, NUDOCS 9806110255 | |
| Download: ML20248L586 (4) | |
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W$LF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard President and Chief Executus Officer JUN 51998 WM 98-0049 U. S. Nuclear Regulatory Commission ATTU:
Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter dated May 6, 1998, from William D. Johnson, NRC, to O. L. Maynard, WCNOC
Subject:
Docket No. 50-482:
Response to Notice of Violation 50-482/9810-11.
Gentlemen:
l This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) l response to Notice of Violation 50-492/9810-11.
Violation 9810-11 identified a failure to properly post an area that permitted access to a high radiation area with dose rates of approximately 400 mrem /hr and immediate corrective actions which failed to barricade the entrance.
This letter also provides discussion of issues concerning the use of the Operations Evolution Checklist and the use of pre-job ALARA checklists.
WCNOC' s response to this violation and the aforementioned discussion are provided in the attachment.
If you have any questions regarding this response, please contact me et (316) 364-8831, extension 4000, or Mr. Michael i
J. Angus at extension 4077.
Very truly rs, OtlytM Otto L. Maynard OLM/rir Attachment ec:
W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a K. M. Thomas (NRC), w/a 9006110255 900605 PDR ADOCK 05000482 f
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P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 l
An Equal opportunity Employer M/FMCNET o_-___--___-__
Attachmsnt to WM 98-0049
, Paga 1 of 3 Response to Violation 50-482/9810-11 Violation 50-482/9810-11:
" Technical Specification 6.12 requires, in part, that high radiation areas in which the intensity of radiation is equal or less than 1000 mR/h at 45 cm (18 in.) from the radiation source shall be barricaded and conspicuously posted as a high radiation area.
Contrary to the above, on April 10, 1998, an accessible high radiation area on the radwaste building roof with a dose rate of approximately 400 mR/r at 18 in. was not posted as a high radiation area and, when it was discovered and posted as a high radiation area, was not barricaded."
Description of Events:
)
During a routine walkdown by a Health Physics superviscr on Friday, April 10,
)
1998, a scaffold to the outside of the Radwaste Storage Building was found posted " Radiation Area-Contact HP Prior to Entry."
The supervisor questioned if the Radwaste Building roof was accessible from the Radwaste Storage E. 1 ding roof, and if dose rate surveys had been performed.
Review of the documentation indicated that the Radwaste Storage Building roof had been surveyed on March 26, 1998. However, the Radwaste Building roof had not been surveyed.
A Health Physics technician was dispatched and determined that the roofs were accessible to each other, and surveyed the Radwaste Building roof.
That survey indicated dose rates from 80 mrem /hr up to 500 mrem /hr on the Radwaste Building Roof.
The area was subsequently posted as a High Radiation Area (HRA) on April 10, 1998.
The area was not barricaded to prevent inadvertent entry to the roof area until later that evening when it was reccgnized the posting was inadequate.
Therefore, the Radwaste Building roof was accessible to station personnel from March 26, 1998, through April 10, 1998.
Logs were reviewed to determine if the roof had been accessed.
The logs indicated the Radwaste Storage Building roof was accessed on April 7, 1998, to perform maintenance on an air conditioning unit; however, a survey was conducted and work area dose rates were <2 mrem /hr.
An HP technician was present during that time to ensure the dose remained ALARA.
Reason for Violation:
The root cause of both examples in this violation involved personnel error.
The mindset of the individuals involved resulted in inadequate evaluation of a condition, followed by inadequate decision making in correcting the adverse condition.
A dose gradient was identified during the initial survey of the Radwaste Storage Building roof near the Radwaste Building roof.
The decision was made to utilize continuous Health Physics coverage to maintain ALARA and to ensure the postings were not blown off the roof.
This action was taken to prevent personnel from entering areas of elevated dose rates.
Although station personnel were kept away from the Radwaste Building roof, the entrance was not posted and barricaded to prevent unauthorized entry into a High Radiation Area.
With respect to the failure to adequately barricade the identified high radiation area, the Senior Health Physics Technician dispatched to obtain the dose rates and to properly post access to the roof had a fear of heights.
This l
fear created anxiety and confusion, preventing him from satisfactorily I
completing the task. However, the fear was not made known to Health Physics supervision.
Another contributing factor to the failure was the mindset of a Junior Health Physics Technician sent to verify postings.
The Junior Technician limited his review to only the posting inserts.
The individual relied on the judgment of i
I IL-
Attachment to WM 98-0049 Pega 2 of 3 the Senior Health Physics Technician, rather than objectively questioning if the area was properly posted and barricaded.
n Corrective Steps Taken and Results Achieved:
On April 10, 1998, at 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />, the scaffolding leading to the Radwaste Storage Building roof was posted, "High Radiation Area-notify HP prior to entry; specific Radiation Work Permit (RWP) required for entry," after dose rates were found to be >100 mR/hr.
After the area was discovered posted as a High Radiation Area (HRA) without a barricade, the accessible sides of the ladder were then barricaded and two additional postings were hung.
This action was completed on April 10, 1998, at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br />.
Health Physics personnel reviewed the shift logs and surveys to determine if the roof had been accessed.
This review indicated that the roof had been accessed on April 7,
1998; a survey performed during that activity indicated that the work area dose rates were <2 mrem /hr.
An investigative team was formed to examine other similar events that have recently occurred.
Interviews were conducted to determine if generic human performance factors were hindering performance.
No generic human performance errors related to these events was discovered.
However, the team did provide recommendations for enhancing human performance in the Health Physics area.
This information was captured in Performance Improvement Request 98-1027.
The results of the interviews are being reviewed by an industrial physiologist to confirm the team's findings.
Other areas in the plant were reviewed to determine if similar access conditions existed. None were identified.
Corrective Steps To Be Taken:
=
Based on the investigative team's findings and recommendations, a Health j
Physics supervisor will serve as a field coach for the remainder of 1998.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved when accurate postings and barricades were installed on the Radwaste Storage Building roof, and the ladder to access the roof, on April 19, 1998, at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br />.
ALARA Checklists and Irradiated Specimen Removal Paragraph thirteen of the Executive Summary and section R3.1 (page 18) of the report summary provided discussion associated to the use of ALARA checklists and contingency plans for the irradiated specimen shipment.
The inspection discusses a process where movement of an irradiated reactor vessel specimen was to be performed.
The report documents contingency actions of grasping the specimen by hand to physically assist inserting the specimen into a cask should the need arise.
The remainder of the inspection report discussion is based on this action.
WCNOC's Pre-Job Briefing addressed the contingency if the specimen movement was stopped or if problems came up during the move.
Inspection Report 98-10 stated that the contingency plan was to grab the specimen by hand.
However, the Reactor. Engineer actually stated he would grab the long handled specimen removal tool to physically insert the specimen into the shipping cask.
During the Pre-Job Briefing evaluation, the potential dose to insert the specimen with l
the long handled tool was evaluated.
Time was estimated by the individual to be 30 seconds.
Health Physics personnel calculated a dose of 133 mrem to the Whole Body based on one minute.
Therefore, the doses would not have been
Attachment to WM 98-0049 Paga 3 of 3 1
within the range necessary to warrant the use of the ALARA Checklist.
Procedure AP 25B-300, "RWP Program," does not require an ALARA Checklist be in%tiated if the total dose for the job is less than 1 man-rem.
However, RPP 02-105, *RWP," requires a Pre-Job Briefing for any work performed in or with access to a Locked High Radiation Area (LHRA) or, a Hot Particle Area (Zone 3).
The dose rate anticipated from the specimen was up to 30 rem /hr, which qualified it to be classified as a LHRA.
The spent fuel pool in which the specimen was stored is a posted Hot Particle Area.
Based on the potential risk associated with the job the HP Supervisor required a Pre-Job Briefing.
A specific RWP was initiated based on a LHRA and potential risk.
The intent of the ALARA Checklist is for the Job Coordinator and the work group ALARA Representative to use the checklist during the pre-planning of the job.
The Pre-Job Briefing form (APF 25B-300-08) is used to ensure that all radiological aspects of the job are considered.
Its purpose is to ensure jobs that nave a high risk potential are evaluated, even though the dose expended may be minimal.
The Pre-Job Briefing for this job adequately covered items considered on the Pre-Job ALARA Checklist.
==
Conclusion:==
The PRE-Job Briefing more than adequately addressed the radiological concern associated with this job even though the total dose received was less than 0.050 man-rem.
There were no procedural requirements to perform a Pre-Job ALARA checklist.
The presumption documented in the inspection report is based on a
miscommunication between the system engineer and the inspector.
At no time did the work documents provide for grasping the specimen by hand.
Therefore, the doses would not have been within the range necessary to warrant the use of the ALARA - Checklist.
In addition, the activities associated to the pre-planning and pre-job briefing were equivalent to the activities performed with the checklist.
Use of Operations Evolution Checklist Paragraph four of the Executive Summary and Section 07 (page 4) of the report summary provided discussion associated to Self-Assessment Report SEL 98-003,
" Effectiveness.of the Operations Evolution Checklist."
The inspection report presents a position that, due to changes recommended from the Self-Assessment being incorporated, the checklist had become less effective.
The Operations Evolution Checklist was originally developed for use when a troubleshooting request or a request to perform a procedure is received to help ensure complete communications take place.
From interviews with personnel using the checklist, it has been determined that some of the questions are not applicable, some are covered procedurally in AP 21-001 " Operations Evolution Practices", or are covered in the work package.
Some of the questions are the responsibility of the personnel requesting permission to perform the activity and the accountability for those items rests with that person and their supervisor.
The revised " Evolution Screening Checklist" provides a more concise list of questions that ensure complete communications take place prior to performing the activity.
The Evolution Screening Checklist is used as a tool to prompt communication and thought processes.
The recommendations made in the Self Assessment provided for better alignment of the checklist with the actual processes and made the checklist a more useful tool.
It is WCNOC's belief that the checklist remains effective and will be used in the future with meaningful results.
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