ML20206M094

Responds to NRC Re Violations Noted in Insp Rept 50-482/88-25.Corrective Actions:Procedure Hph 04-077 Being Revised to Provide Clarification of Set Up Following Filter Change Out & Require Logging Background & Alarm Setting

ML20206M094
Person / Time
Site:	Wolf Creek
Issue date:	11/21/1988
From:	Bailey J WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ET-88-0170, ET-88-170, NUDOCS 8811300404
Download: ML20206M094 (4)

Text

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W$LF CREEK NUCLEAR OPERATING CORPORATION John A. Baby Vce Preedom Ergewomgord W S m Noverrber 21, 1988 ET 88-0170 U. S. Nuclear Regulatory Commission i

ATTN: Doc um e nt Control Desk l

Mail Station Pl-137 l

Washington, D. C. 20555 i

Reference:

Letter dated October 21, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC

Subject:

Docket No. 50-482 :

Response to Violation 482/8825-01 j

and 02 Gentlemen:

The purpose of this letter is to transwit Wolf Creek Nuclear Operating Corporation's response to violations 482/8825-01 and 02 which were documented in the Ref srence.

Violation 482/8825-01 involved the f ailure to follow procedures and violation 482/8825-02 involved the f ailure to leak test radioactive sources.

If you have any questions concerning this ta a t t e r,

please contact me or Mr. O. L. Maynard of my staf f.

Vcey truly yours, Q

AA.

9811300404OgOO PDR ADOCK O 02 J hn A. Bailey i

PNV Vice President O

Engineering & Technical Services JAB /jad Attschment cc B. L. Bartlett (NRC), w/a i

D. D. Chamberlain ( NRC), w/a i

R. D. Martin (NRC), w/a D. V. P ick e t t ( N RC). w/a q

__ B _ _ _

Am Ep C*p:rt.ruty Enever M F KMT

Attachment to ET 88-0170 Page 1 of 3 Violation (482/8825-01): Failure to Follow Procedures FJn,d_inj TS 6.11 req. ires that "Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposures."

Licensee Procedure HPH 04-077, "Operation and Calibration of the Eberline AMS-3, req uire s, in part, that the alarm on the portable AMS-3 continuous airborne radioactivity monitor (CAM) be set to alarm at 10 percent above b ack g rounnd.

Contrary to the above, the NRC inspectors determined on both September 13 and September 15,

1988, that the alarms on several AMS-3 CAMS were incorrectly set high, and that the alarm on one CAM would not respond to an alarm test because the alarm setpoint was set of f scale high.

Reason For Violation:

The root cause for the incorrect alarm setpoint has been attributed to nonlicensed utility persennel error.

Procedure HPH 04-077 "Operation and Calibration of the Eberline AMS-3",

did not clearly state that a filter change out required initial set up of the continuous air monitor (CAM).

For initial set up following filter change on a CAM, the CAM must be allowed to run for approximately one hour before setting the alarm setpoint.

This allows the filter to reach equilibrium background prior to setting the alart.

Adjusting the setpoint to 10% above background when the filter was changed would cause actuation of the alarm in 1-2 hours.

Personnel error was involved in that when the alarm d8d actuate due to b2ckground variations,

the technicians would adjust the alarm setpoint to a higher level af ter determining the cause of the alarn and not recheck the CAM at a later time when background decreased to restore the setpoint to 10%

above background.

The CAM which was fuund with the alarm setpoint set off scale high was doe to the setpoint being adjusted above a continously increasing high background and not being returned to a lower setpoint when the f 'uctuating background decreased.

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Attac'hment to ET 88-0170 Page 2 of 3 d

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Corrective Steps Which Have Been Taken and Results Achieved:

revised to require the alans to be set at approximately The procedure was 500 CPM above background. Technicians and HP Supervisors were made aware of i

the change and are periodically checking the slarm set points to ensure that thay are approximately 500 CPM above the varying background.

t C_orrec tive S,t,eys_Vhich Will Be Taken; _To_ Avoid Furthe r Violat ions :

Procedure HPH 04-077 is being revised to provide clarification of set up following litter change out.

Additionally, this revision will requfre logging the background and alarm setting and will provide guidance on actions to be taken upon receipt of an actual alarm condition.

Date When Full Comgliance Will Be Achi_eved:

Revision 3 to HPR 04-077 will be completed by December 9,1988.

i Violation (482/8825-02):

F,ailu re_ _t o Le ak Te s t Ra d io a_c t i v e_ So u rc e s Finding:

TS 4.7.9.1 requires, in part, that "Each sealed source shall be tested for leakage and/or contamination by the licensee.

TS 4.7.9.2.a

requires, in part,

that, "Each category of sealed sources shall be tested

. at least once per 6 months".

This applies to sources in use or prior to being placed in use from storage.

Contrary to the above, the NRC inspectors determined on September 15,

1988, that four sources, not in storage, containing 400 microcuries each of strontium-90 had not been leak tested for a period exceeding 18 months.

Reason For Violation:

The reason for violation is cognitive personnel error by a previous Health Physics Supervisor f ailing to properly interpret TS requirements for testing sealed sources. Personnel involved are no longer employed at the Wolf Creek Generating Station.

A cont ributing factor to the event was the nature of the semiannual leak test procedure that starts with the list used the preceding time and updates it as required. This tended to perpetuate an error once in t rod uc ed.

, At t a c'hmen t to ET 88-0170 Page 3 of 3 Corrective Steps Whici. Have Bee _n Taken and Results Achieved:

The semiannual leak test procedure (STS HP-001) has been revised to have a list of all sources that require leak testing included in the procedure.

The source receipt procedure (HPil 02-001) has been revised to require the list o' sources in STS HP-001, which require a leak test, be updated upon source receipt.

Correct _ive Steys Which_Will Be Taken _To Avoid Further Violations:

The corrective steps mentioned above should prevent any further violations for not leak testing sources.

Date When Full Comg11ance Will Be Achieved:

Full compliance has been achieved.

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