IR 05000382/1993030
| ML20058D914 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/26/1993 |
| From: | Thomas C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9312060093 | |
| Download: ML20058D914 (4) | |
Text
{{#Wiki_filter:_ _ . _ _ __ . . __ pa atCog UNITED STATES . NUCLEAR REGULATORY COMMISSION f '. ' f '
l , f k'ilgspt'rf,j Rociou iv
- d f
611 RYAN PLAZA DRIVE, Sulf E 400 f ARLINGTON, TEXAS 760118064 j
,%r g)y 261993
- "*
' i i ! Docket: 50-382 License: NPF-38 I l Entergy Operations, Inc.
'[ l ATTN: Ross P. Barkhurst, Vice President i Operations, Waterford ! ' P.O. Box B i Killona, Louisiana 70066 ! I i SUBJECT: NRC INSPECTION REPORT 50-382/93-30 ! i Thank you for your letter of November 18, 1993, in response to our l letter and Notice of Violation dated October 15, 1993. We have reviewed'your l l i ! reply and find it responsive to the concerns raised in our Notice of l i Violation. We will review the implementation of your corrective actions j during a future inspection to determine that full compliance has'been achieved and will be maintained.
, l ! l I
Sincerely, j i i gh Y WAV .
i ' Cecil 0. Thomas, Acting Director Division of Radiation Safety . and Safeguards ~
cc.
Entergy Operations, Inc.
- ATTN: Harry W. Keiser, Executive l
Vice President & Chief Operating Officer , P.O. Box 31995 i Jackson, Mississippi 39286-1995 i Entergy Operations, Inc.
I ATTN: Jerrold G. Dewease, Vice President
Operations Support P.O. Box 31995 i Jackson, Mississippi 39286 l l l 9312060093 931126
r PDR ADOCK 05000382 J l Q PDR i ' -.. - ... - l
i
. - \\ . . j s . Entergy Operations, Inc.
-3-bec. to DMB (IE06). \\ \\ . bec w/ copy of license'e's letter dated November 12, 1993: J. L. Milhoan WAT Resident Inspector Section Chief (DRP/0) Project Engineer (DRP/D) Section Chief (DRP/TSS) Lisa Shea, RM/ALF, MS: MNBB 4503 DRSS-FIPS File MIS System ' RIV File L. T. Ricketson, DRSS/FIPS R. A. Scarano, RV/DRSS 010052 i RIV:FIPS M O C:FJPS f DD:pRSSj f AD:JRSS / LTRicketIonInh Ma[ (k M ain ddm7s i //Aff93 k'?/d}93 , if BH93 19/2493
~,- . . .. ,- - - -.. - . .. .-- - - . -..- ., . [ <- , -
- ..
. l- . I i
Entergy,Ooerations, Inc.
-2-l Wise, Carter, Child & Caraway - ATTN: Robert B. McGehee, Esq.
t P.O. Box 651 ! Jackson, Mississippi 39205 j i Entergy Operations, Inc.
! A1TN: D. F. Packer, General-l Manager Plant Operations l P.O. Box B
Killona, Louisiana 70066 ' Entergy Operations, Inc.
l ATTN: L. W. Laughlin
Licensing Manager i P.O. Box B ! Killona, Louisiana 70066
! Chairman ! Louisiana Public Service Commission ! One American Place, Suite 1630 . i Baton Rouge, Louisiana 70825-1697 i ! Entergy Operations, Inc.
ATTN: R. F. Burski, Director l Nuclear Safety ~ P.O. Box B I Killona, Louisiana 70066 Hall Bohlinger, Administrator . Radiation Protection Division l P.O. Box 82135 . 70884-2135 l l Baton Rouge, Louisiana
Parish President
St. Charles Parish ! P.O. Box 302
Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 Winston & Strawn ATTN: Nicholas S. Reynolds Esq.
1400 L Street, N.W.
Washington, D.C.
20005-3502 ,,. . . - - .
- ~ . - -. -.. - - - -- .. - - . . _ -. ... _. _ _ _ _, -{ !- t -
- . ., , Entergy.0perations, Inc.
-3-i bec to DMB (IE06) ! i l bcc w/ copy of licensee's letter dated November 12, 1993- ! l J. L. Milhoan l WAT Resident Inspector j Section Chief (DRP/D) i Project Engineer (DRP/D) i Section Chief (DRP/TSS) ! Lisa Shea, RM/ALF, MS: MNBB 4503 l DRSS-FIPS File-l MIS System l RIV File ! L. T. Ricketson, DRSS/FIPS i R. A. Scarano, RV/DRSS , , ! I
l \\ ' i I t i ! '! , I ! ! ! l l ' l l l ! ,
l RIV:FIPS M O C:FJPS - DD:pRSL ( AD:JRSS / LTRicketsonIn[ Ma[ h h mberlain d d hs ///A93 W/6df93 (f BH93 f.7 /2493 i --. _ _ -.
, __ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _. _ . __, h - e L
- ~ ENTERGY l"'L"e ""*" '"*'
l c . K. tina L A 70M6 ~! f Tei 504 739 6~74 i R. F. Burski ! [*Ct v r vr>v s,ey i "Aih"M*"j 3 ' l j-W3F1-93-0198 l E I 8993 'dl ^4
' 4-PR , ,%: REGIONIV ' , November 12, 1993
i ! U.S. Nuclear Regulatory Commission . .{ l ATTN: Document Control Desk i Washington, D.C. 20555 l i Subject: Waterford 3 SES l Docket No. 50-382 License No. NPF-38 i
NRC Inspection Report 93-30 l l Reply to Notice of Violation { i !
Gentlemen: j i In accordance with 10CFR2.201, Entargy Operations, Inc. hereby submits in l Attachment I the response to the violation identified in Appendix A of the ! subject Inspection Report.
[ l ! If you have any questions concerning this response, please contact ! C.J. Thomas at (504) 739-6531.
i \\ l Very truly yours, J . . . . R.F. Burski Director Nuclear Safety RFB/CJT/ssf Attachment hh lJ.,O Milhoanf.(NRC Recjion IIVI, D.L. Wigginton '(NRC-NRR), cc: . R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office- , l , - - l ,-- _ . . - - -. .. ... -. . ~.. .., -._ -
__, ... _ _.. _ __ _ ._ _ ,
.: Attachment to
.c W3F1-93-0198
-
Page 1 of.4 ATTACHMENT 1 ! ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN i APPENDIX A 0F INSPECTION REPORT 93-30 ! ! ! ! VIOLATION NO. 9330-01 i !
Technical Specification 6.8.1, requires that written procedures be ' established, implemented, and maintained covering the activities referenced i in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
! Section 7.e.(4) of Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978 lists radiation protection procedures for contamination ! control.
{ i 1.
Procedure HP-002-704, Rev. 4, " Personnel. Decontamination,"' Step i 10.1.2.3.A, states, "That-for cases of skin contamination of the l l facial area,...take or instruct the individual' to take, nasal wipes l l of each nostril using cotton-tipped swabs."
j , Contrary to the above, no nasal wipes were obtained from individuals f who were identified as having facial contamination on September 25, i 1992, and on July 29, 1993.
! ! I 2.
Procedure HP-002-704, Rev. 4, " Personnel Decontamination, " Step i 10.1.2.6, states, in part, " Skin / clothing contamination is considered i no longer present as evidencec' 'ay <100 cpm / probe area by direct j frisk... When this limit can be met, then the individual can be j released."
! ! Contrary to the above, final surveys conducted of individuals with i skin contamination on February 19, 1992, and July 29, 1993, reported the residual contamination following decontamination as "<1000 cpm," indicating that the individuals may have been released with skin contamination greater than 100 cpm / probe area.
3.
Procedure HP-002-704, Rev. 4, " Personnel Decontamination, " Step
10.3.3.6, requires, in part, that part 2 of the Skin Decontamination Report be completed by denoting the date/ time the affected area was resurveyed after attempting decontamination.
. i , ,., ,-w . w, ,. ,, ..,, -, - -
. .,- Attachment to i.c W3F1-93-0198 - ' Page 2 of 4 , , Contrary to the above, the dates and times that resurveys were i ( conducted following decontamination of individuals were not dt ~ '.trd I on July 23, 1993, and on February 17, 1992.
RESPONSE (1) Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause was personnel error in that both initiators and reviewers > of Skin Decor,tamination Reports failed to adhere to the requirements of Procedure HP-002-704.
, , A potential contributing cause of this violation is that Procedure
l HP-002-704 is difficult to use Specificall/, the procedure contains I human factor weaknesses relating to procedure clarity and Skin [ Decontamination Report format.
(2) Corrective Steos That Have Been Taken and the Results Achieved ! The cited failures to implement Procedure HP-002-704 involved five different Skin Decontamination Reports.
Each Skin Decontamination Report was evaluated to determine needed follow-up actions.
The results of these evaluations are as follows:
1.
Report 92-1 failed to denote the date and times of resurveys following decontamination of an individual on February 17, 1992. Although specific resurvey times cannot be reconstructad, two presumptions are viable based on other data within the report.
First, the resurveys were taken on the date that the individual became contaminated.
Second, the individual was decontaminated within a short time of occurrence. These two presumptions in concert with the low level of contamination (e.g., 300 cpm / probe area on left palm), I indicate that no consequential exposure occurred.
2.
Report 92-2 reported the final survey of residual contamination of an individual following decontamination on February 19, 1992, as "<1000."
Consequently, the report indicates the individual may have been released with skin contamination i greate than the acceptable level of <100 cpm / probe area.
An interview with the technician who performed the final survey concluded that the contaminated individual was decontaminated to <100 cpm / probe area. Apparently, the technician erroneously recorded "<1000" which would have been appropriate when counting a smear. The technician failed to correctly use cpm i '
. _______ _ _ _ ' .- Attachm:nt to . y, f W3F1-93-0198 ' ' Page 3 of 4 units applicable to skin contamination limits.
Instead, the
technician applied the more often used dpm units applicable to '
' recording clean smear results. The report was corrected to l indicate the proper units.
t 3.
Report 92-49 failed to denote the date and times of resurveys l following decontamination of an individual on September 25, i 1992. Additionally, although the report documents a case of skin contamination of the facial area, no nasal wipes were obtained from the individual as required by procedure.
i ! Although specific survey times cannot be reconstructed, it can be concluded that the surveys were taken on the date cf occurrence. The individual did receive a whole-body count as l j required.
, 4.
Report 93-8 reported the final survey of residual contamination i of an individual following decontamination on July 29, 1993, as l "<1000 dpm."
Consequently, the report indicates the individual ' may have been released with skin contamination greater than the acceptable level of <100 cpm / probe area. Additionally, although the report documents a case of skin contamination of the facial area, no nasal wipes were obtained from the individual as required by procedure. An interview with the technician involved concluded the contaminated individual was i decontaminated to <100 cpm / probe area. Apparently, the technician erroneously recorded "<1000 dpm" which would have l been appropriate when counting a smear.
As in the case of Report 92-2, the technician failed to correctly use cpm units applicable to skin decontamination limits and instead applied i the more often used dpm units applicable to recording clean smear results. The report was corrected to indicate the proper units. The individual did receive a whole-body count as required.
! 5.
Report 93-9 failed to denote the date and times of resurveys l following decontamination of an individual on July 29, 1993.
Although specific resurvey times cannot be reconstructed, two presumptions are viable based on other data within the report.
First, the resurveys were taken on the date that the individual became contaminated.
Second, the individual was decontamir.ated within a short time of occurrence. These two presumptions in concert with the low level of contamination (e.g., 300 cpm / probe area on face), indicate that no consequential exposure occurred.
i
._ ._ _ -. _ _ _ ... _ - . _ ._ o ., Attachment to l ,
- - *
- .,, }, W3F1-93-0108 . Page 4'of 4 . ! - A review of other Skin Decontamination Reports generated since i January 1,1992, was conducted to identify similar conditions.
l Similar discrepancies were found on a number of reports.
The most j frequent discrepancy identified was no dates and times for surveys.
.I The discrepancies noted were evaporative and therefore'non-l correctable.
- )
! l The discrepancies noted involved a large percentage of the Radiation ! Protection staff. As a result, Radiation Protection management , discussed this ev.:nt and procedure compliance expectations with the _ Radiation Protection staff, i (3) Corrective Steps Which Will Be Taken to Avoid Further Violations j i l Procedure HP-002-704 will be evaluated for human factoring enhancements and revised as appropriate.
Included in this~ revision l will be resolution of current procedure inconsistencies regarding , acceptance criteria, clarified guidance for nasal! smear acquisition and assay, and follow-up guidance for required whole-body counts.
, (4) Date When Full Compliance Will Be Achieved I l Full compliance will be achieved by Dec. ember 30,_1993.
-l l l }}