IR 05000382/1997002

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-02

ML20141G765
Person / Time
Site:	Waterford
Issue date:	05/19/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-02, 50-382-97-2, NUDOCS 9705220486
Download: ML20141G765 (5)

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9....8 AR LINGToN, TE X AS 76011 8064 MAY I 91997 l

Charles M. Dugger, Vice President a Operations - Waterford 3 l

Entergy Operations, In '

P.O. Box B l Killona, Louisiana 70066 l

SUBJECT: NRC INSPECTION REPORT 50-382/97-02 l Thank you for your letter of April 23,1997, in response to our letter and Notice of I

Violation dated March 24,1997. Based on discussions with the radiation protection superintendent on May 9,1997, we understand that corrective actions for the failure to '

perform surveys also included training to radiation protection personnel and additional surveys of containers within the protected area. 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 Sincerel p

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homas. P. Gwyn / Dir ctor Division of Reacto ects Docket No.: 50-382 License No.. NPF-38 /

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Executive Vice President and Chief Operating Officer Entergy Operations, In P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President, Operations Support Entergy Operations, In P.O. Box 31995 Jackson, Mississippi 39286-1995 9705220486 970519 PDR

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. I Entergy Operations, In Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations l Waterford 3 SES j Entergy Operations, In !

P.O. Box B l Killona, Louisiana 70066

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Manager - Licensing Manager l Waterford 3 SES I Entergy Operations, In I P.O. Box B Killona, Louisiana 70066 Chairman Louisiana Public Service Commission )

One American Place, Suite 1630  !

Baton Rouge, Louisiana 70825-1697 Director, Nuclear Safety &

Regulatory Affairs  :

Waterford 3 SES Entergy Operations, In P.O. Box B Killona, Louisiana 70066 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 i

Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish j P.O. Box 302 l Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center i Suite 610 Bethesda, Maryland 20814

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Entergy Operations, In MAY l 91997

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bec to DCD (IE01) l, bcc distrib. by RI Regional Administrator  : Resident inspector DRP Director . DRS-PSB

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J DOCUMENT NAME: R:\_WAT\WT702AK.LAK To receive copy of nocument. Ind6cate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy j RIV:PE:DRP/ D, C:DRP/D _ n D:DRP ,_1\) , <

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OFFIC:AL RECORD COPY l

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3 Entergy Operations, In MAY I 91997 bec to DCD (IE01)

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Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)

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DOCUMENT NAME: R:\_WAT\WT702AK.LAK To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/ 0, C:DRP/D _

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W3F1-97-0086 l A4.05 PR April 23,1997

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ATTN: Document Control Desk u

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Washington, D.C. 20555 24I9997 L

Subject: Waterford 3 SES L REG!O F ^'

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Docket No. 50-382 --

l License No. NPF-38 NRC Inspection Report 50-382/97-02 i Reply to Notice of Violation ,

Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violations identified in Enclosure 1 of the subject inspection Repor Should you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-666 Very truly yours, Y

Lv E.C. Ewing Director, Nuclear Safety & Regulatory Affairs ECE/GCS/tjs Attachment cc: f E.W.'Merschoff (NRC Region iV), C.P. Patel (NRC-NRR),

R.B. McGehee, N.S. Reynolds NRC Resident inspectors Office TT- OMT W L{D S & 5BQ

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Attrchment to W3F1-97-0086

. Page 1 of 4 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 9702 VIOLATION NO. 9702-07 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be presen Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiatio CFR 20.1902(a) requires that the licensee post each radiation area with a conspicuous sign bearing the radiation symbol and the words " CAUTION RADIATION AREA."

Contrary to the above, as of Februaly 18,1997, the licensee did not perform surveys required by 10 CFR 20.1501 that resulted in a failure to post " CAUTION RADIATION AREA" signs as required by 10 CFR 20.1902(a) after transferring radioactive material to Sealand Container 21248- This is a Severity Level IV violation (Supplernent IV) 50-382/9702-0 RESPONSE (1) Reason for the Violation The root cause of this violation is personnel error in that an individual inadvertently failed to follow the requirements of procedure HP-001-201,

" Radiological Survey Techniques and Frequencies," which states that radiation surveys should be performed after job / plant evolutions are performed that may change radiation levels and when deemed necessary by Radiation Protection Supervision. In addition, as a consequence of not performing the required radiological survey, the affected area was not pested as required by procedure HP-001-219, " Radiological Posting Requirements" The individual who was involved with this event was tasked with assisting craft personnelin preparation of refueling activities. One of his tasks involved I ~ _ _ _ _

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Att: chm:nt to W3F1-97-0086 8, Page 2 of 4 moving vacuum cleaners from a radioactive waste compactor building to a nearby Sealand trailer. The dose rate on one of the vacuums was 120 mr/hr l on contact. In addition to this task, the individual was asked to stage an area to support work on contaminated equipment in the compactor building. The individual moved the vacuum cleaners to the Sealand trailer and then staged a contaminated area in the compactor building as requested. In his haste to stage the contaminated area in the compactor building, the individual forgot to ;

perform a radiological survey for the area near the Sealand trailer and as a i result did not post the area as require !

(2) Corrective Steps That Have Been Taken and the Results Achieved 1 The area around the Sealand container was surveyed as required and j

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properly posted as a Radiation Area.

- The individual who failed to perfcrm the required survey and subsequent posting was counsele I (3) Corrective Steps Which Will Be Taken to Avoid Further Violations Waterford 3 believes that the above corrective steps are adequate to avoid further violations of this typ l (4) Date When Full Compliance Will Be Achieved Waterford 3 is in full complianc !

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ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 9702 J

VIOLATION NO. 9702-08 10 CFR 20.1904(a) requires the licensee to ensure that each container of licensed materials bears a durable, clearly visible label bearing the words " CAUTION, RADIOACTIVE MATERIAL," or " DANGER, RADIOACTIVE MATERIAL."

Contrary to the above, on February 18,1997, a 95 cu ft container of contaminated .

protective clothing located behind the tool room in the protected area did not bear a ;

label with the words " CAUTION, RADIOACTIVE MATERIAL," or " DANGER, '

RADIOACTi\/E MATERIAL."

This is a Severity Level IV violation (Supplement IV) 50-382/9702-08.

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RESPONSE I (1) Reason for the Violation

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The root cause of the violation is indeterminate in that the events which led to the label not being on the 95 cu. ft container cannot be ascartained. It is clear, based on worker observation and recent self assessments of the containers, that the label was at one time affixed to the containe #

There are three plausible causes of this occurrence. One cause, and possibly ]'

he most probable, is that a Radiation Protection worker removed the label to update it or to make it more legible and forgot to place a label back on the container. Another possible cause is that the adhesive on the label material ;

was not adequate enough to maintain the label on the container while i exposed to weather conditions (i.e. humidity, fluctuating temperatures, rain, etc.). Finally, an unauthorized individual may have removed the label from the i containe (2) Corrective Steps That Have Been Taken and the Results Achieved j The container was properly labeled with a radioactive labe . Radiation Protection personnel reviewed other areas and determined that no containers were missing label i l

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' Attachment to W3F1-97-0086

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' Labels with higher bonding strength have been ordered to be used on l'

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^ This event was d:3 cussed with appropriate Radiation Protection -

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) personnel and the importance of restoring imbch; an containers was emphasized.

4 W3's management discussed at an "All Hands Meeting" for site

personnel that unauthorized individuals should not operate or tamper -

with radiological posting (3) Corrective Steps Which Will Be Taken to Avoid Further Violations ,

Waterford 3 believes that the above corrective steps are adequate to avoid

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further violations of this type.

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j .(4) Date When Full Compliance Will Be Achieved j

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l Waterford 3 is in full compliance.

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