IR 05000313/1992025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/92-25 & 50-368/92-25

ML20126L070
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/04/1993
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Yelverton J ENTERGY OPERATIONS, INC.
References
NUDOCS 9301070330
Download: ML20126L070 (5)

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. NUCLEAR REGULATORY COMMISSION

REGION IV

8 611 RYAN PLAZA DRIVE, SUITE 400

< [ AR Lt NGTON, T E XAS 76011-8064

+..** JAN 4 1993 Docket Nos. 50-313 50-368 License Nos. DPR-51 NPF-6 Entergy Operations, In ATTN: J. W. Yelverton, Vice President Operations, Arkansas Nuclear One Route 3, Box 137G Russellville, Arkansas 72801 SUBJECT: NRC INSPECTION REPORT 50-313/92-25; 50-368/92-25 Thank you for your letter of December 9,1992, in response to our letter and Notice of Violation dated November 9,1992. 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,

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- . J. Ca 1 n, Director

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Division f Radiation Safety and Saf uards cc:

Entergy Operations, In ATTN: Donald C. Hintz, President &

Chief Operating-Officer P.O. Box 31995 Jackson, Mississippi 39286 (170Obd

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93o1070330 930104 3 DR ADOCK 0300 /I)

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Entergy Operations, In Entergy Operations, In ATTN: John R. McGaha, Vice President Operations Support P.O. Box 31995 Jackson, Mississippi 39286 Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es P.O. Box 651 Jackson, Mississippi 39205 Entergy Operations, In ATTN: R.-A. Fenech, General Manager Plant Operations Route 3, Box 137G Russellville, Arkansas 72801 Entergy Operations, In ATTN: James J. Fisicaro Director, Licensing Route 3, Box 137G Russellville, Arkansas 72801 Honorable Joe W. Phillips County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & St' awn ATTN: Nichclas S. Reynolds, Es L Street, Washington, Arkansas Department of Health

. ATTN: Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management 4815 West Markham Street Little Rock, Arkansas 72201-3867 B&W Nuclear Technologies

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ATTN: Robert B. Borsum Licensing Representative 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 Admiral Kinnaird R. McKee, USN (Ret)

214 South Morris Street Oxford, Maryland 21654

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Entergy Operations, In *

-3-ABB Combustion Enginee.ing Nuclear Power ATTN: Charles 8. Brinkman Manager, Washington Nuclear Operations 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 l

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Entergy Operations, In 'bec to DMB (IE06)

i bec distrib. by RIV w/ copy of licer.see's letter dated December 9,1992:- j J. L. Milhoan B. Murray, DRSS/FIPS i

L. T. Ricketson, FIPS DRP Section Chief, DRP/A Project Engineer, DRP/A-Section Chief, DRP/TSS ,

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MIS System FIPS File RIV File Lisa Shea, RM/ALF (MS MNBB 4503)

T. Alexion, NRR Project Manager (MS 13 H3) '

R. Bevan, NRR Project Kinager (MS 13 H3)

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2- Rou'e 3 Box 137G Operations usewn naoi Te Q1 W 3100 December 9, 1992 OCAN129201 U.S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington,.DC 20555 SUBJECT: Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Report 50-313/92-25; 50-368/92-25 Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the response to the violation identified during the inspection of activities associated . tith the failure of workers to attend pre-job briefings required by Radiation Work Permit Should you have questions or comments, please call me at 501-964-860 r Very truly yours, ml $M James J. Fisicaro Director, Licensing JJF/RMC/mmg attachment

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December _9, 1992 OCAN129201- Page 2

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cc Mr. James L. Milhoan U. S. Nuclear Regulatory Commission Region IV-611-Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident' Inspector Arkansas. Nuclear One ANO-1 & 2 Number 1, Nuclear Plant Road 1 Russellville, AR 72801 Mr. Thomas W. Alexion NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail'Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Roby B. Bevan, J .

NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555-Rockville Pike Rockville, Maryland 20852

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OCAN129201 Pcgo 2 l

(2) Corrective steps taken and results achieved:

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On October 8, 1992, a review of RWPs was conducted to determine compliance with pre-job briefing requirement This review identified additional discrepancies relating to pre-job briefing For immediate corrective action, instructions were provided to radiation protection personnel on October 9, 1992, requiring all radiation workers be asked, prior to their being added to an RWP if their RWP requires a pre-job briefin If a pre-job briefing is required, a Health Physics supervisor is required to verify that the proper documentation is completed. The supervisors are not to add individuals to an RWP that requires a pre-job briefing unless the appropriate documentation has been completed. This action will remain in-place until further actions to prevent recurrence 'are complete A memorandum issued on November 23, 1992, from the Vica President, Operations, to ANO plant personnel, re-emphasized the importance of the pre-job briefing requirements, completion of the associated documentation, and the respansibility of each individual to ensure that they have the pre-job briefing as specified by their RW (3) Corrective steps which will be taken to prevent recurrence:

An evaluation of the general employee radiation worker training program has been completed. This evaluation was conducted to determine if the radiological pre-job briefing requirements are adequately communicated to radiation workers. The evaluation identified several recommendations to enhance the general employee radiation worker training program. Implementation of these reco-nmendations will be completed by December 31, 199 An evaluation of the existing radiological pre-job briefing procedures has been complete This evaluation determined that additional procedure enhancements are needed to identify, conduct, and document pre-job briefings. The necessary procedure changes to implement these enhancements will be completed by January 15, 199 An evaluation of the existing administrative controls available through command functions on the existing Radiological Exposure Management (REM) computer system has been completed. This evaluation determined that access to radiological controlled areas (RCA) can be restricted when pre-job briefing requirements are in effect for a specific RWP. Implementation of any necessary software modifications will be completed by March 31, 199 I l

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OCAN129201 _Page 1

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NOTICE OF VIOLATION

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Unit 2 Technical Specification, 6.8.1 requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. Item 7e.(1)

of Appendix "A" of Regulatory Guide 1.33, February 1978 listed access controls to radiation areas including a radiation work permit system as a procedure to be include Procedure 1000.031, Revision 15, " Radiation Protection Manual," required that " individuals are responsible for: . . .

adherence to radiological protection requirements ... " and

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... being knowledgeable of and understanding the requirements and contents of the Radiological Work Permit (RWP) under which work will be performed."

Radiation Work Permit 921392 stated, " Personnel performing

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work governed by this Radiological Work Permit will be required to attend a radiological pre-job briefing."

Contrary to the above, on October 8, 1992, the inspector identified approximately 20 people performing work in Unit 2 governed by Radiation Work Permit 921392 who had not attended radiological pre-job briefing This is a Severity Level IV violation. (Supplement IV)

(368/9225-01)

Response to violation 368/9225-01 (1) Reason for the violation:

A pre-job briefing at ANO is defined as an "ALARA" tool used to minimize exposure to radiation workers, minimize -

radwaste generation and to reduce the amount of problems ~

and unknowns associated with the individual job. This allows the work crew to anticipate problems that otherwise would arise at the job site in a higher radiation dose rate fiel The cause of the violation was determined to be a failure to follow procedures, related to Radiation Work Permits (RWPs), in that radiation workers failed to attend and/or document their participation in pre-job briefings as required by Health Physics (HP) procedure Inconsistencies in the implementation and administration of pre-job briefings were considered to be contributing factors related to following RWP requirements. The primary type of radiation workers violating pre-job briefing requirements were determined to be contract personnel.

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Attactunant' to:'

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- Additionally, an ongoing project _to_ develop an__ improved

REM computer system is-in progres The new-system will

- provide enhancements related to the' implementation, -

administration-and development of RWP requirement (4) Date when full compliance will be achieved:

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Full' compliance was achieved on October 9,- 1992,.when-instructions were' issued to Health Physics-personnel-requiring confirmation that pre-job briefing requirements had been met prior to adding workers to_the RWP.-

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bec distrib. by RIV w/ copy of licensee's letter dated December 9,.1992:

J. L. Milhtan B.'Murray, DRSS/FIPS L. T. Ricketson, FIPS DRP Section Chief, DRP/A Project Engineer, DRP/A Section Chief, DRP/TSS DRS MIS System FIPS File RIV File Lisa Shea, RM/ALF (MS MNBB 4503)

T. Alexion, NRR Project Manager (MS 13 H3)

R. Bevan, NRR Project Manager (MS -13 H3)

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