IR 05000482/1997014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-14 .Finds Reply Responsive to Concerns Raised in Nov. Will Review C/As During Future Insp

ML20198Q295
Person / Time
Site:	Wolf Creek
Issue date:	11/06/1997
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-97-14, NUDOCS 9711120166
Download: ML20198Q295 (4)

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SUBJECT:

NRC INSPECTION REPORT 50 482/97 14

Dear Mr. Maynard:

Thank you for your letter of October 31,1997,in response to our letter and Notice of Violation dated October 2,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the impicmontation of your

corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, w

.D.Joh n,

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Project Branch B Division of Reactor Projects Docket No.: 50 482 License No.: NPF-42 cc:

Chief Operating Officer Wolf Creek Nuclear Operating Corp.

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If P.O. Box 411 Burlington, Kansas G6839 I

Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 E

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Wolf Creek Nuclear

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Operating Corporation

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Supervisor Licensing Wolf Creek Nuclear Operating Corp.

P.O. Box 411 j

Burlington, Kanses 66839 Chief Engineer Utilities Division

Kansas Corporation Commission

i 1500 SW Arrowhead Rd.

Topeka, Kansas 66604-4027 i

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Office of the Governor i

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Topeka, Kansas 66612

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Attorney General

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Judicial Center l

301 S.W.10th 2nd Floor Topeka, Kansas 66012 1697 County Clerk Coffey County. Courthouse Burlington, Kansas 66839 1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611 1287

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L Wolf Creek Nuclear-3-

Operating Corporation NOV - 61997 bec to DCD (IE01).

bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B)

DRS PSB Project Engineer (DRP/B)

MIS System Branch Chief (DRP/TSS)

RIV File

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DOCUMENT NAME: R:\\_WC\\WC714AK.JFR

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"E" = Copy wth enclosures "N" = No copy RIV:PE:DPR/B C:DRP/B DNGraves;dfp WDJohnson[p(p

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OFFICIAL RECORD COPY

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Wolf Creek Nuclear-3-Operating Corporation NOV - 61997

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Regionel Administrator Resident inspector

DRP Director SRI (Callaway, RIV)

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Branch Chief (DRP/B)

DRS PSB Project Engineer (DRP/B)

MIS System Branch Chief (DRP/TSS)

RIV File

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DOCUMENT NAME: R:\\_WC\\WC714AK.JFR To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DPR/B C:DRP/B

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OFFIC:AL RECORD COPY t:nc53

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W@ NUCLEAR OPERATING LF CREEK

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Clay C Warren Chef Operstify Officer

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WO 97-0120 i

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October 31, 1997

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U. S. clear Regulatory Commission l

ATTN:

Document Control Desk

Mail St.ation F1-137 Washington, D. C.

20555 Reference:

Letter dated October 2, 1997, from T.

P. Gwynn, NRC, to 0. L. Maynard, WCNOC l

Subject:

Docket No. 50-482:

Response to Notice of Violations j

50-482/9714-01, 9714-03, and 9714-05

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Gentlemen i

j This atter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

response to Notice of Violations 50-482/9714-01, 9714-03, and 9714-05.

Notice

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i of Violation 9714-01 cites inef fective maintenance of a procedure to support l

implemertation of Technical Speification Amendment 108.

Notice of Violation l

9714-03 cites an exampie of a radiation worker failing to have the correct

dosimetry required by the Radiation Work Permit.

Notice of Violation 9714-05 j

addresses a failure to perform surveys of radiation levels in unrestricted and controlled areas.

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WCNOC's response to these violations is provided in the attachment.

If you have any questions regarding thir response, please contact me at ;316) 364-

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8831, extent.ien 4000, or Mr. Richard D.

Flannigan at extension 4500, i

j Very truly y rs, b

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i C1 C. Warren j

CCW/jad Attachment

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D. Johnson (NPC), w/a

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E. W. Merschoff (NRC), w/a J.

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Ringwald (NRC), w/a h. M. Thomas (NRC), w/a

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P.O. Box 411/ Burlington, KS 66839 / Phone- (316) 3644831

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An Equal opportunity Employer M F HC. VET

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At t echnont to WO 97-0120 Pege 1 of 6

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Violation 50-482/9714-01:

" Technical Specification 6.8.1.a requires, in part, that written procederes be established, implemented, and maintained covering the

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I applicable procedures recommended in Appendix A of Regulatory Guide I

1.33, Revision 2, February 1978.

Regulatory Guida 1.33, Revision 2,

February 1978, Section 3.f.,

recommends, in part, that procedures be established for the operation of containment.

Surveillance Procedure STS GP-007,

"CTMT Penetration Isolation Verification,"

has been established in accordance with these requirements.

Contrary to the above, on August 20, 1997, Procedure STS GP-007, "CTMT Fenatration Isolation Verification," was not effectively maintained in that the licensee implemented Technical Specification Amondment 108, which relocated a list of containment isolation valves from Technical Specification 3.6.3 to Procedure STS GP-007, without providing adequate guidance for how this procedure would subsequently be used to identify containment isolation valves covered by Technical Specification Limiting Condition for Operation 3.6.3."

Reason for Violation:

The implementation of Technical Specification (T/S) Amendment 108 on August 19, 1997, resulted in the inability of the Control Room personnel to properly implement Technical Specification (T/S) 3.6.3).

On August 28, 1997, Control Room personnel became concerned with the operability of valve BM HV-36 during the performance of procedure STS IC-616B, "SLV RLT TST K616 Safety Injection."

This valve was identified in the Equipment out of Service Log as a T/S 4.0.5 failure.

The Shift Supervisor (SS) reviewed the applicable system drawings, T/S Amendment 108, and the physical location of the valve (the first valve inside containment) and conservatively determined that valve BM HV-36 was a containment isolation valve. The SS instructed the valve be closed and tagged with Clearance Order 97-1047-BM until additional reviews could be completed on day shift.

Day shift personnel subsequently reviewed Updated Safety Analysis Report Figure 6.2.4-1, and determined that valve BM HV-36 was not a containment isolation valve.

Day shif t personnel then removed Clearance order 97-1047-BM.

Due to Control Room personnel questicns and concerns with compliance to T/S 3.6.3, Operations management decided that STS GP-007,

"CTMT Fenetration Isolation Verification," was the governing procedure for iraplementation of T/S Amencment 108.

This decision process occurred af ter T/S Amendment 108 was released for implementation.

The cause of this event is inadequate change management cf program implementation.

Evaluation of this event disclosed examples of ineffective planning, communication, ownership, and implementation.

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Attachman? 'o WO 97-0320 Pege 2 of t,

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Corrective Steps Taken and Results Achievedt Procedure STS GP-007, "CTMT Penetration Isolation Verification," was revised October 4,

1997, to clearly specif y which valves are cont a i nt.,ent isolation valves.

Operations management has provided guidance to operating crews concerning the effects of Amendment IJB on cor.tainment ieolation valves.

l Corrective Steps That Will Be Takent Licensing will coordinate treetings to discuss the current license amendment

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requests which have been submitted, but not approved, as well as license amendment requests currently in process.

These meetings will assure that apptcpriate ownership of each amendment and that implementation activities have been considered prior to receipt and implementation of the amendments.

This is an interim measure to ensure amendments are properly implemented which will be effective until the procedure revision described below is completed.

In addition, Procedure AP 268-001, " Revisions to the Operating License and/or Technical Specifications," will be revised to ensure tha following actions occur 1. 1.mendment ownership is established 2. Pre-submittal meetings are held to dis, cuss amendment implementation 3. Ownership is established for implementation activities 4. Post amendment receipt meetings are conducted to review pre-submittal decisions and ensure Wolf Creek is prepared to implement the amendment.

This revision will be completed by January 31, 1996.

Date When Full Compliance Will Be Achievedt WC110C is currently in full compliance, i

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Attachmont to WO 97-0120

Page 3 of 6

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i violation 50-482/9714-03:

"10 CFR 20.1302(a) requires, in part, that the licer.see reake or cause to be made, surveys of radiation levels in unrestricted and controlled areas to demonstrate compliance with the dose limits for individu*l members of the public in paragraph 20.1301.

Contrary to the above, on Septenber 16, 1997, the licensee moved a spent resin liner without first performing a survey of the radiation levels in the unrestricted area adjacent to the restricted area south of the radwaste building.

A subsequent evaluatian estimated the dose rate in the unrestricted area well in excess of the limit of 10 CFR 20.1301."

Reason for Violation Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of 10 CFR 20.1301 and 10 CFR 20.1302 occurred.

However, a subsequent evaluation has shown that the dose rates identified in 10 CFR 20.1301 were not exceeded at the unrestricted area boundary.

This clarification is necessary because a clear unoerstanding of the location of the unrestricte. **usdary and the radiologic.nl controlled area (RCA) boundary was not ade qua t el.,

communicated to the inspector. NRC Inspection Report 97-14 and Notice of Violatien 9714-03 reflect this misunderstanding.

1:ealth Physics personnel comtrunicated clarifying informaticn to the NRC Senior Resident Intpector on October 8, 1997 This event involved the transfer of a High Integrity Container (HIC) from a process shield to a shielded tranrport cask on September 16, 1997.

During the transfer process the HIC was remcVed from one shielded area and transferred to another shielded area.

It was * luring this evolution that the radiation levels increased in the RCA because the HIC was not shielded during the transfer process.

For this evolution one Health Physics empivyee was placed at the southeast and southwest corners of the RCA to monitor the radiological conditions and halt any traffic along the access road adjacent to the south side of the Radwaste Building during the HIC movement evolution.

Each Health Physics employee carried a survey meter and was qualified to operate the survey meter.

However, since they were not Health Physics Technicians, they could use the survey meters for personal anformation only and were not allowed to parforra

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surveys.

The radiation levels observed where the personnel were stationed was 1.5 mrem /hr.

This was below the 2 mrem /hr. limit specified by 10 CFR 20.1301 and 20.1302.

The Hcalth Dhysics employees halted one Security officer on foot, two Security of ficers cn bicycles and one truck during the approximately fif teen minute ew olutiers.

10 CFR 20.1301 specifies that,

"The total effective dose equivalent to

individual members of the public from the licensed operation does not exceed

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0.1 rem in a year," and "The cose in any unrestricted area from external sources does not exceed 0.002 rem in any one hour."

Compliance with the dose limits are specified by 10 CFR 20.1302(a) as, "The 'icensee shall make or cause to be made, as appropriate, surveys of radiation levels to unrestricted and controlled areas...to demonstrate compliance with the dose limits for individual members of the public in 20.1301."

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Attachment to WO 97-0120 Page 4 of 6

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Procedure AP 25A-001, " Radiation Protection Manual," step 4.34, defines the restricted area as bounded by the Security fence (protected area boundary).

The calculation for the RCA boundary dose rate previously provided to the resident inspector was understood by the NRC Resident Inspector as the unrestricted area boundary dose rate.

A new calculation was performed using the protected area fence as the unrestricted area boundary and the result was 1.5 mrem /hr or 0.38 mrem for the 15 minute evolution.

The nuw calculations demonstrate the unrestricted area boundary was maintained below the limits specified by 10 CFR 20.1301 and 1302, however, there were no surveys to demonstrate compliance as required by 10 CFR 20.1302(a).

AP 25A-200, " Access to Locked High or Very High Radiation Areas," step 4.3 defines a transient locked high radiation area as transfer of items that are

> 1 rem /hr at 12".

These areas will not be posted during transfer as long as 3 Health Physics Technician is in direct surveillance of the areat step 6.6 discusses transient or temporary locked high radiation areas not controlled by red flashing lights or keys.

These areas shall have continuous direct surveillance to prevent unauthorized entry.

The cause of this event is lack of procedural guidance to perform surveys in the unrestricted areas for the purpose of monitoring ionizing radiation in excess of 10 CFR 20 limits.

Corrective Steps Taken and Results Achieved Performance Improvement Request (PIR) 97-2839 was initiated to address this issue.

Corrective Actions initiated to address PIR 97-2839 include the performance of a review of 10 CFR 20 and a comparison to existing procedures to determine any additional areas of missed guidance.

This review was completed on October 14, 1997 No areas of missed guidance were found.

As an interim measure, until procedure RPP 02-210, " Radiation Survey Methods,"

is revised, Health Physics personnel will conduct the following activities when moving HICs Access to effected areas within the restricted area will be controlled and

surveys will be performed.

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Surveys of the unrestricted area will be performed and access will be

restricted to those areas when radiation levels exceed 10 CFR 20 limits.

• RWP 970019 pre-jeb checklist has been revised to caution individuals to survey unrestricted areas if dose rates are exceeded at the RCA boundary.

Corrective Steps That Will Be Takent Procedure RPP 02-210, will be revised to incorporate guidance on surveys of unrestricted areas.

Date When Full Compliance Will Be Achieved-WCNOC is currently in full compliance.

The procedure revision for these changes will be complete by January 30, 1998.

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httechmsnt to UO ')7-0120 Page 5 of 6

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Violation 50-492/9714-05:

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• Technical Specification 6.11 requires, in part, that radiation workere adhere to procedures for personnel radiation protection consistent with the requirements of 10 CrR Part 20.

Administrative Procedure AP 25B-100,

' Radiation Worker Guidelines,'

Revision 4,

Section 6. 3. 6, states that ' Individuals shall comply with the RWP [ Radiation Work Permit) requirement.'

Contrary to the above, on August 28, 1997, a worker entered the radiologically controlled area without the electronic dosimetry required by Radiation Work Permit 970009."

Reason for Violation l

On August 28, 1997, an individual arrived at Access Control to enter the RCA for a tour of the pump and tank rooms on the 1974' elevation of the Auxiliary Building.

Upon arrival, he found the area around the book containing copies of the Radiaticn Work Permits (RWP) to be congested, j

After signing into the Radiological Controlled Are.n (RCA)

through the Automated Radiological Access Control System the individual was able to access the RWP book and review RWP 970009.

Upon completion of the review, the individual performed a cursory check for proper t'Osimetry. The individual procteded towards the RCA boundary.

During this time the individual was engaged la an on and off conversation, which distracted the individual from the sign-in process.

After accessing the pump and tank rooms, the individual was in transit to the

"B" Centrifugal Charging Pump room, the individual noticed that the electronic dosimeter (PD-1) was not in place.

The individual immediately exited the a.rea, along with another raclation worker whv had been with the individual, and notified the Health Physics Shift Technician.

The PC-1 was located in the rack of the computer station where the individual had signed into the RCA.

Based on the other radiation worker's PD-1, who had been with the individual the entire time, the individual was assigned a dose of zero mrem.

The cause of this event was the inattention to detail caubed by distractions during the RCA sign-in process.

A contributing factor was the lack of a strong continuing training program for all radiation workers, Corrective Steps Taker. and Results Achieved:

The worker notified the Health Physics Shift Technician immediateJ y upon discovering the dosimetry discrepancies.

This resulted in a potential reduction of exposure, and allowed Health Physics personnel to evaluate and perform corrective action in a more timel) menner.

Dose calculations were performed for the worker.

No exposure resulted from

the incident.

• WCNOC is currently monitoring and challenging ' workers entering the RCA.

This is a short term action that will be implemented until further evaluation can be performed.

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Attachmant to Wo 97-0120 Page 2 of 6

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"Just-In-Time" training has been conducted to rei.nf orce Radiation Protection policies and supplement radiation worker training.

This training included a practical f actors qualification for radiation workers to demonstrate the correct login, dre:s out, undress and RCA exit procedures.

• The Manager Radiation Protection has given direction for Health Physics personnel to question radiation workers on expected standards.

The Health Physics Access Control area has been declared a "No Talk Zone"

to minimize distraction of radiation tarkers entering the RCA.

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a Security of ficer has been assigned to the Health Physics Accebs Control j

to verify radiation workers entering the RCA are wearing proper dosimetry.

• Corrective Steps To Be Taken In an effort to improve human performance in the Access Control area, WCNOC Health Physics personnel will submit a proposed facility change to be evaluated using the design change process.

This proposal will be submitted by January 1, 1998.

Date When Pull Compliance Will Be Achieved:

WCNOC"is currently in full compliance, c

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