IR 05000482/1988009: Difference between revisions

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{{Adams
{{Adams
| number = ML20151N932
| number = ML20197F394
| issue date = 04/11/1988
| issue date = 06/02/1988
| title = Insp Rept 50-482/88-09 on 880314-18.Violation Noted.Major Areas Inspected:Solid Radwaste Program,Transportation Activities & Low Level Radwaste Storage Facilities
| title = Ack Receipt of Util Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/88-09
| author name = Baer R, Murray B
| author name = Callan L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Withers B
| addressee affiliation =  
| addressee affiliation = WOLF CREEK NUCLEAR OPERATING CORP.
| docket = 05000482
| docket = 05000482
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-482-88-09, 50-482-88-9, NUDOCS 8804260046
| document report number = NUDOCS 8806130088
| package number = ML20151N900
| title reference date = 05-13-1988
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 9
| page count = 2
}}
}}


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In Reply Refer To:
APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
Docket: 50-482/88-09 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:
Thank you for your letter of May 13, 1988, in response to our letter and Notice of Violation dated April 15, 1988. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine


==REGION IV==
Sincerely, Original Signed By  ,
NRC Inspection Report: 50-482/88-09 Operating License: NPF-42 Docket: 50-482 Licensee: Wolf Credk Nuclear Operating Corporation (WCNOC)
A. B. Beach p
P.O. Box 41 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)
      '
Inspection At: WCGS Site, Burlington, Kansas Inspection Conducted: March 14-18, 1988 Inspector: _ / ~  // [
L. J. Callan, Director Division of Reactor Projects cc:     1 Wolf Creek Nuclear Operating Corporation   '
g R. E. Baer, Senior Radiation Specialist Date '
ATTN: Otto Maynard, Manager    j of Licensing    ;
Facilities Radiological Protection Section
P.O. Box 411 Burlington, Kansas 66839     !
    '
Wolf Creek Nuclear Operating Corporation ATTN: Gary Boyer, Plant Manager
Approved: /   / fr
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P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN: Robert D. Elliott, Chief Engineer Fourth Floor, Docking State Office Building Topeka, Kansas 66612-1571 Kansas Radiation Control Program Director bec: , see next page)  g RIV:A PS:RPSB C:R C:DRP/A D:DRP@
B. Murray, Chief, Facilities Radiological Dare /
REBaer/jt BJ4ur DDChamberlain LJCallan ( /gy/88 6 /g /88 ji#(/88 G/\ /88 g\
Protection Section Inspection Summary Inspection Conducted March 14-18, 1988 (Report 50-482/88-09)
8806130088 880602    b PDR ADOCK 05000482 Q  DCD    fy hU
Areas Inspected: Routine, unannounced inspection of the licensee's solid radioactive waste program, transportation activities, and low-level radioactive waste storage facilitie Results: Within the areas inspected, one violation was identified (failure to lock a high radiation area, paragraph 6).


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DRP RPSB RIV File DRS MIS System RSTS Operator Lisa Shea, RM/ALF Section Chief B. Murray R. L. Bangart R. E. Hall Project Engineer, DRP/A B.DeFayette, RIII        ;
Callaway, RIII P. O'Connor, NRR Project Manager i
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DETAILS Persons Contacted WCNOC
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   *B. D. Withers, President
e e W4) LF  NUCLEAR CREEL I"3N7  ) OPERATING C   MAY l 8 lb68 I i i Barl D. Withers       w  a ere.o.nieno CNef Executive Omcor      I_
  *G. D. Boyer, Plant Manager
May 13, 1988 WM 88-0128 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Reference: Letter dated April 15, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC Subject: Docket No. 50-482 : Response to Violation 482/8809-01 Gentlemen:          .
  *T. M. Damashek, Supervisor, Quality Surveillance
Attached is a detailed response to Violation 482/8809-01        which was documented in the Referenc Violation 482/8809-01 involved the failure to lock a high radiation are If you have any questions concerning this matter,  please contact me or Mr. O. L. Maynard of my staf Very truly yours, Bart D. Withers President and BDW/jad    Chief Executive Officer Attachment cc: B. L. Bartlett (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), w/a (2)
  *C. M. Estes, Manager, Operations J. D. Freeman, Radwaste Supervisor
  ~~
  *C. .J. Hoch, Quality Assurance (QA) Technologist
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  *C. F. Kesinger, Training Program Coordinator (Health Physics (HP))
RO. Box 411/ Burtogton, KS 66839 / Phone: (316) 364 8831 h  An Equal Opporumy E@yer M FHGVET
  *E. Lehmann, Engineer, Technical Staff
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  *R. L. Logsdon, Site Chemist
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  *C. M. Medenciy, HP Supervisor, Radwaste
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  *B. McKinney, Manager, Technical Support
  *J. F. McMahon, Supervisor, Technical Training
  *T. S. Morrill, Site HP
   *C. E. Parry, Manager, QA
  *C. G. Patrick, Supervisor, Quality Systems
  *G. J. Pendergrass, Licensing _ Engineer
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Williams, Manager, Plant Support
  '
Zell, Manager, Nuclear Training h,<C
  *B. L. Bartlett, Senior Resident Inspector A. W. Grella, Office of Nuclear Material Safety and Safeguards (NMSS)
M. E. Skow, Resident Inspector D. M. Sollenberger, NMSS
  * Denotes those individuals present at the exit interview on March 18, 198 . Licensee Action on Previously Identified Inspection Findings (Closed) Violation (482/8717-01): Failure to Provide Radwaste Retraining
   - This item was identified in NRC Inspection Report 50-482/87-17 and involved the failure to provide radwaste retraining to the HP supervisor-radwaste. The licensee provided retraining in November 1987 in the NRC/ Department of Transportation (D0T) regulations, transportation requirements, and burial site license criteri (Closed) Violation (482/8717-02): Failure to Maintain HP Training Records
  - This item was identified in NRC Inspection Report 50-482/87-17 and involved the failure to maintain complete up-to-date records of training activities. The licensee had updated the training records to include the


missing training courses for the individuals concerne .
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Attachment to WM 88-0128 Page 1 of 2 Violation (482/8809-01): Failure to Lock a High Radiation Area Finding:
Technical Specification 6,.12.2 requires that areas assessible to . personnel with radiation levels greater than 1000 mrem /hr at 18-inches from the radiation source. shall be provided with locked doors  to preveat unauthorizied entry.


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Contrary to the above, on March 17, 1988, an NRC inspector determined that a
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) high radiation area greater than 1000 mrem /hr (1300 mrem /hr) at 18 inches from the radiation source on the portable demineralizer located in the. low level drum storage area of the radwaste building was not provided with a      ,
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locked door to prevent unauthorized entry into the are Reason for Violation:
Technical Specification 6.12.2 states, "For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that -
are located within large areas, such as PWR containment, where no enclosure ~+
          ;
exists for purposes of locking, and where no enclosure -can be reascaably      '
constructed around the individual area, the individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device".


3. Inspector Observations The following are observations the NRC~ inspector discussed with the licensee. These observations are neither violations nor unresolved' item These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that these items would be reviewe Training Records - The licensee computer printout of an individual's training history provides a course code number, but no description of the course. See paragraph 5 for additional. detail Use of Temporary Hose - The licensee uses long lengths of temporary hose for transferring radioactive spent resins, evaporator bottoms, and radioactive liquids to the portable demineralizer and the high integrity containers (HIC) in preparation for shipment of radicactive waste. See paragraph 6 for additional detail Shipping Cask Users Manual - The licensee did not maintain a working copy of the users manual for casks being used to ship radioactive waste in the radwaste supervisors /HP supervisor-radwaste office. See paragraph 8 for additional detail Shipping Document Checklist - The licensee did not provide a shipping docue nt or supervisor's review checklist for radioactive material /radwaste packages. See paragraph 7 for additional detail . Organization and Management Controls-Radwaste (83722/83522}
Wolf Creek Nuclear Operating Corporation (WCNOC) considered the low level l
The NRC inspector reviewed the licensee's staff functional assignments including: organization, responsibilities, authorities, staffing, identification and correction of weaknesses, audits and appraisals, communication to employees, and documentation and implementation relating to solid radioactive waste and transportation programs to determine compliance with NRC Bulletin 79-20 and Technical Specification (TS)
drua, storage area which contained the portable demineralizer to be a la ge      j area in accordance with Technical Specification 6.12.2. The low level irum l
Sections 6.22 and 6.5, and commitments in Chapters 13.1 and 13.4 of the Updated Safety Analysis Report (USAR).
storage area of the radwaste building, containing    the portable  ;
".emine ra liz e r , wa's barricaded with yellow and magenta barrier tape, conspicuously posted, and an activated flashing light was present as a      l warning device per the large area criteria of Technical Specification 6.1 During the inspectivn in which this situation was identified,    the NRC informed WCNOC that they did not consider this ares to be a large area and a violation would be issued for not providing a locked door to prevent unauthorized entry into the are Corrective Step _s Which Have Been Taken and Results Achieved:
As a result of the NRC identified concern, a locked high radiation area boundary was established at the door controlling entry into the south end of     1 the radwaste building, expanding the controlled are ,
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The NRC inspector reviewed those procedures and documents listed in Attachment The NRC inspector noted that the licensee's procedures, which appear adequate for regulatory compliance, could contain additional information to provide a better working document, such as in Procedure HP 09-505, Section 4.3 which states, "Perform a general survey of the item (s) to be packed to determine radiation levels for proper placement inside the container. Note: Care must be taken to ensure that area postings are not violated and the container will not exceed D0T requirements." The
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Attachment to WM 88-0128 Page 2 of 2 Corrective Steps Which Will Be Taken To Avoid Furthh.r Violations:
The door to the south end of the radwaste building has been maintained locked when the radiation levels are greater than 1000 mrem /hr at 18 inches from the radiation sourc Additionally, a work request had been written two weeks prior to the NRC Inspector's arrival to pursue having an enclosure built around the portable demineralizer ski This work request has been submitted to Nuclear Plant Engintering for evaluation and subsequent issuance of a Plant Modification Request, if deemed appropriat Date When ' Full Compliance Will Be Achieved:
Full compliance has been achieve .
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licensee did not state what the 00T requirements were or the applicable D0T paragraph (173.441) that applie No violations or deviations were identified, f Training and Qualifications-Radwaste (83723/83523)
The NRC inspector reviewed the licensee's training program including:
  ' adequacy of training, employee knowledge, qualification requirements, new employees, INP0 accreditation, audits and appraisals, training not covered by INP0, and transportation /radwaste training for personnel involved in the transportation of radioactive material and solid radioactive waste activities to determine compliance with the requirements of NRC Bulletin 79-20 and TS Section 6.4, and commitments in Chapter 13 of the USA The NRC inspector discussed with licensee representatives the computer printout of individual training record The present printout provided the course code, date completed, and grade information, but without a course code book it is not possible to determine what each entry references. The time required to determine the training a single individual received could require between 1/2 to 1 hour, which does not include reviewing the specific course lesson plan. The licensee acknowledged the training printout was not user friendly and agreed that changes would be made to assist in the auditing of training record The NRC inspector reviewed lesson plans for training provided and select training records of personnel in operations, maintenance, quality control,
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and HP who are assigned to radioactive waste processing and transportation activitie The NRC inspector reemphasized that the training requirements as specified in NRC Bulletin 79-20 are applicable to all individuals who are involved in the transfer, packaging, and transport of radioactive material and this training should be received prior to the individuals involvement in these activitie No violations or deviations were identifie . Solid Radioactive Waste (84722/84522)
.
The NRC inspector reviewed the licensee's solid radioactive waste program including: processing and storage; audits and appraisals; program changes; construction and installation of solid waste system; liquid l
leakage, overflow, and spillage; sampling; preoperational test program; completion of preoperational test; procedures; disposition of low-level waste; and installation, calibration, and testing of process monitors to
;
determine compliance with commitments in Chapter 11 of the USA The NRC inspector discussed with licensee representatives the prolonged use of temporary rubber hose used to connect the permanent radwaste transfer piping system to tLe HIC, dewatering equipment and portable demineralizer skid. The licensee does not perform any periodic testing or
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have a preventative maintenance program to ensure hose integrit The NRC inspector noted that the hose used to transfer spent resin is run through a drain trough, which affords protection to the hose and would help contain a leak, most of the way to the dewatering equipmen '
The NRC inspector determined that the licensee submitted and received approval for their process control program (PCP) on April 17, 1985, and the current PCP, Revision 4, had been included in the Semiannual Radioactiva Effluent Release Report for July 1 through December 31, 1986, as required by TS 6.13.1 and 6.1 TS 6.12.2 requires that areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 18 inches from the radiation source shall be provided with locked doors to prevent unauthorized entr The NRC inspector determined during a routine inspection of the radwaste building on March 17, 1988, that room 7225, the low-level drum storage area, located on the 2000-foot elevation of the Radwaste Building contained the Duratek portable demineralizer skid in the northeast corner of the room. This area was not provided with locked doors to prevent unauthorized entry. The demineralizer skid was a posted high radiation
, area with barrier rope and a flashing light installed on the southwest corner of the skid shield. The room also was a posted high radiation area at the sliding door which is routinely left in the open position because of mechanical problems with the opening / closing system. The highest recorded radiation level within the room was 40 mrem /hr on the March 10, 1988, weekly room survey. The latest radiological survey on the Duratek demineralizer skid, February 24, 1988, indicated a radiation intensity of 3500 mrem /hr at contact and 1300 mrem /hr at 18 inches from a filter tan The NRC inspector discussed with licensee representatives that the failure to provide locked doors was considered an apparent violation of TS 6.1 (482/8809-01). The licensee stated they considered this a large area and conspicuously posting and a flashing light would meet the TS requirement The NRC inspector stated that the area could be locked at the sliding door or an enclosure could be constructed around the individual area as specified in the TS. The licensee later stated that a work request had been submitted about 2 weeks prior to the NRC inspector's determination for construction of an enclosure around the demineralizer skid.
 
l Radioactive Waste Management (84850)
The NRC inspector reviewed the licensee's program for disposal of
, low-level radioactive waste (LLRW) including: management controls, l quality control program, manifests, classification, form and
! characterization, shipment labeling, tracking of shipments, and disposal site license conditions to determine compliance with the requirements of 10 CFR Parts 20.311, 61.55, and 61.56.
 
. The licensee uses the "radman" computer program for determinations of l waste classification and managing the LLRW program. The NRC inspector
 
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noted that the licensee had updated the waste classification program in November 1987 from waste stream samples analyzed by an approved vendo The licensee was not solidifying waste, spent resins were being dewatered in a HIC and shipped to a burial sit The NRC inspector reviewed the waste shipment document packages located at both the HP supervisor-radwaste office and at records management. The NRC inspector noted that these document packages were complete, but there was not a checklist that indicated what documents were in each package or that the package had received any supervisory revie The NRC inspector reviewed the licensee's records for LLRW shipped since 1985. The following tabulation shows the total volume of LLRW shipped for the period 1985 through 198 Year  Volume - Cubic Feet  Curie Content 1987  450 .521 1986  610 .368 1985  0  0 No violations or deviations were identifie . Transportation (86721)
The NRC inspector reviewed the licensee's prograni for transportation of radioactive materials including: audits and appraisals, procedures, procurement and lease of packaging, implementation of the transportation program, and transportation incidents to determine compliance with the requirements of 10 CFR Part 7 '
The NRC inspector determined the licensee was a registered user for all packages used for the transport of radioactive material. The licensee maintained a controlled copy of the certificate of compliance and users manual in the document control room. The NRC inspector discussed with licensee representatives the desirability to maintain a copy of the users manual with the HP supervisor-radwaste. The users manual contains specific information on: what items have to be inspected prior to use of i the package, tests that need to be performed, and the last time gaskets were replaced and tests performed. The manual also provides procedures to perform these tasks. The licensee stated they would review the NRC inspector's obser.ation and provide a copy of the users manual for those cask routinely used for the HP supervisor-radwast The licensee had not experienced any transportation incidents which caused a reduction in the effectiveness of packaging since the previous inspectio No violations or deviations were identifie . - .
 
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L    , Transportation Activities (86740)
The NRC inspector reviewed the licensee's transportation activities program including: management controls, training program, audits and reviews, procurements and selection of packaging, quality assurance-program, preparation of packages for shipment, delivery of completed packages to carrier, receipt of packages, periodic maintenance of packaging, and records and reports to determine compliance with the requirements of 10 CFR Parts 20 and 71, and 00T Regulations 40 CFR Parts 170-18 No violations or deviations were identifie . Low-Level Radioactive Waste Storage Facility (65051)
The NRC inspector reviewed the status of the LLRW storage facility program including: basis for construction, QA program, procedures for construction, organization and staffing, training and qualifications, procedures, and effluent monitoring for compliance with WCGS license conditions and the recommendations of NRC Generic Letter 81-38, NRC Circular 80-18, Regulatory Guide 1.143, and NUREG-080 The NRC inspector determined that the licensee had not completed an onsite LLRW facility. The licensee had shipped approximately 2807 cubic feet of radioactive waste the first 6 months of 1987 and only 1697 cubic feet the second 6 months for a total of 4504 cubic feet. The licensee's present facility appears adequate for the amount of waste presently generated and routine shipments are made so that a large accumulation of LLRW is not being maintaine No violations or deviations were identifie . Exit Interview The NRC inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on March 18, 1988. The NRC inspector summarized the scope of the inspection and discussed the inspection findings, i
 
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- ,    ATTACHMENT 1 PROCEDURES AND DOCUMENTS REVIEWED Procedures ADM 02-013,-Radwaste Coordinator, Revision 1, dated March 11, 1986 ADM 03-950, Radioactive Waste Program, Revision 3, dated February 1,1988 ADM 04-023, Radioactive Releases, Revision 9, dated January 26, 1988 HPH 09-501, Manual Classification of Waste, Revision 4, dated August 5, 1986 HPH 09-502, Manual Curie Content Determination, Revision 3, dated August 5, 1986 HPH 09-503, Collection and Transfer of Radioactive Waste, Revision 3, dated February 25, 1986 HPH 09-504, Packaging of Compactible Solid Waste, Revision 3, dated January 25, 1988 HPH 09-505, Packaging of Noncompactible Solid Waste, Revision 3, dated January 23, 1988 HPH 09-506, Packaging of High Level Filters, Revision 2, dated February 12, 1986 HPH 09-507, Packaging of Wet Solid Waste, Revisioni 3, dated January 21, 1988 HPH 09-509, Marking, Labeling, and Storage of Radwaste Containers, Revision 1, dated September 10, 1985 HPH 09-510, Handling of Cartridge Filters, Revision 6, dated May 22, 1986 HPH 09-511, Use of Drum Inspection Facility, . Revision 2, dated March 19, 1986 HPH 09-512, Incoming Vehicle Surveys, Revision 2, dated March 19, 1986 HPH 09-513, Outgoing Vehicle Surveys, Revision 2, dated March 31, 1986 HPH 09-514, Transport Vehicle Loading and Inspection, Revision 6, dated February 26, 1988 HPH 09-520, Manual Determination of Shipment Type, Revision 2, dated August 5, 1986 HPH 09-521, Shipment of Limited Quantity Materials, Revision 1, dated February 6,1986 HPH 09-522, Shipment of LSA Materials, Revision 1, dated January 28, 1986 HPH 09-523, Shipment of Type A Materials, Revision 1, dated January 28, 1986
 
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HPH 09-524, Exclusive Use Shipment of Type B or HRC Material, Revision 1, dated February 14, 1986 HPH 09-525, Shipment of Empty Packages, Revision 3, dated June 10, 1987 HPH 09-530, Radioactive Materials Shipping Documents, Revision 3, dated June 10, 1987 HPH 09-531, Advance Notifications, Revision 2, dated February 19, 1988 HPH 09-532, Radwaste Reports, Revision 4, dated January 23, 1988 HPH 09-533, Use of Aqua-Set Absorbant, Revision 0, dated June 24, 1986 HPH 09-534, Waste Sampling Procedure, Revision 0, dated February 19, 1988 HPH 09-541, Bead Resin and Activated Carbon Dewatering Procedure for CNSI 14-215 or Smaller Liners, Revision 0, dated March 10, 1988 SYS HB-129, Vendor Liquid Radwaste Processing, Revision 0, dated September 17, 1987 SYS HC-227, Vendor Processing of Primary Resins and Concentrates, Revision 2, dated April 22, 1987 WChP-02, Process Control Program, Revision 4, dated August 27, 1986 Vendor 10-1, System Operation, Revision 3, dated November 13, 1987 Veador 10-2, Adding Media, Revision 3, dated November 13, 1987 l Vendor 10-3, Sluicing Media, Revision 3, dated November 18, 1987 kerdr 10-4, Leak Check, Revision 3, dated November 13, 1987 Audits and Surveillance Reports 50140-K162, Audit - Radioactive Waste Management and Transportation Activities, dated May 6, 1987
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53359 S-1589, Surveillance, Duratek Waste Processing, dated October 28, 1987 53359 S-1513, Surveillance, Resin Transfer and Dewatering, dated December 29,
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1987 i
53359 S-1522, Surveillance, Radioactive Waste Program Records, dated March 4, 1987 53359 S-1586, Surveillance, Ouratek Resin Spill, dated October 23, 1987
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Latest revision as of 23:03, 8 December 2021

Ack Receipt of Util Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/88-09
ML20197F394
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/02/1988
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8806130088
Download: ML20197F394 (2)
v • d • e


Text

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JW - 2 l988

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In Reply Refer To:

Docket: 50-482/88-09 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:

Thank you for your letter of May 13, 1988, in response to our letter and Notice of Violation dated April 15, 1988. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Original Signed By ,

A. B. Beach p

'

L. J. Callan, Director Division of Reactor Projects cc: 1 Wolf Creek Nuclear Operating Corporation '

ATTN: Otto Maynard, Manager j of Licensing  ;

P.O. Box 411 Burlington, Kansas 66839  !

Wolf Creek Nuclear Operating Corporation ATTN: Gary Boyer, Plant Manager

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P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN: Robert D. Elliott, Chief Engineer Fourth Floor, Docking State Office Building Topeka, Kansas 66612-1571 Kansas Radiation Control Program Director bec: , see next page) g RIV:A PS:RPSB C:R C:DRP/A D:DRP@

REBaer/jt BJ4ur DDChamberlain LJCallan ( /gy/88 6 /g /88 ji#(/88 G/\ /88 g\

8806130088 880602 b PDR ADOCK 05000482 Q DCD fy hU

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Wolf Creek Nuclear Operating - -2-Corporation t

bec to DMB (IE 06)

bcc-distrib. by RIV:

R. D. Martin, RA Myron Karman, ELD, MNBB (1)

Resident Inspector Section Chief, DRP/A)

'

DRP RPSB RIV File DRS MIS System RSTS Operator Lisa Shea, RM/ALF Section Chief B. Murray R. L. Bangart R. E. Hall Project Engineer, DRP/A B.DeFayette, RIII  ;

Callaway, RIII P. O'Connor, NRR Project Manager i

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e e W4) LF NUCLEAR CREEL I"3N7 ) OPERATING C MAY l 8 lb68 I i i Barl D. Withers w a ere.o.nieno CNef Executive Omcor I_

May 13, 1988 WM 88-0128 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Reference: Letter dated April 15, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC Subject: Docket No. 50-482 : Response to Violation 482/8809-01 Gentlemen: .

Attached is a detailed response to Violation 482/8809-01 which was documented in the Referenc Violation 482/8809-01 involved the failure to lock a high radiation are If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours, Bart D. Withers President and BDW/jad Chief Executive Officer Attachment cc: B. L. Bartlett (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), w/a (2)

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RO. Box 411/ Burtogton, KS 66839 / Phone: (316) 364 8831 h An Equal Opporumy E@yer M FHGVET

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Attachment to WM 88-0128 Page 1 of 2 Violation (482/8809-01): Failure to Lock a High Radiation Area Finding:

Technical Specification 6,.12.2 requires that areas assessible to . personnel with radiation levels greater than 1000 mrem /hr at 18-inches from the radiation source. shall be provided with locked doors to preveat unauthorizied entry.

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Contrary to the above, on March 17, 1988, an NRC inspector determined that a

) high radiation area greater than 1000 mrem /hr (1300 mrem /hr) at 18 inches from the radiation source on the portable demineralizer located in the. low level drum storage area of the radwaste building was not provided with a ,

locked door to prevent unauthorized entry into the are Reason for Violation:

Technical Specification 6.12.2 states, "For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that -

are located within large areas, such as PWR containment, where no enclosure ~+

exists for purposes of locking, and where no enclosure -can be reascaably '

constructed around the individual area, the individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device".

Wolf Creek Nuclear Operating Corporation (WCNOC) considered the low level l

drua, storage area which contained the portable demineralizer to be a la ge j area in accordance with Technical Specification 6.12.2. The low level irum l

storage area of the radwaste building, containing the portable  ;

".emine ra liz e r , wa's barricaded with yellow and magenta barrier tape, conspicuously posted, and an activated flashing light was present as a l warning device per the large area criteria of Technical Specification 6.1 During the inspectivn in which this situation was identified, the NRC informed WCNOC that they did not consider this ares to be a large area and a violation would be issued for not providing a locked door to prevent unauthorized entry into the are Corrective Step _s Which Have Been Taken and Results Achieved:

As a result of the NRC identified concern, a locked high radiation area boundary was established at the door controlling entry into the south end of 1 the radwaste building, expanding the controlled are ,

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Attachment to WM 88-0128 Page 2 of 2 Corrective Steps Which Will Be Taken To Avoid Furthh.r Violations:

The door to the south end of the radwaste building has been maintained locked when the radiation levels are greater than 1000 mrem /hr at 18 inches from the radiation sourc Additionally, a work request had been written two weeks prior to the NRC Inspector's arrival to pursue having an enclosure built around the portable demineralizer ski This work request has been submitted to Nuclear Plant Engintering for evaluation and subsequent issuance of a Plant Modification Request, if deemed appropriat Date When ' Full Compliance Will Be Achieved:

Full compliance has been achieve .

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