ML20062J901
| ML20062J901 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/12/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0198, W3F1-93-198, NUDOCS 9311180149 | |
| Download: ML20062J901 (5) | |
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Entergy Operations,Inc.
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-PR November 12, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 l
NRC Inspection Report 93-30 Reply to Notice of Violation 1
Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact C.J. Thomas at (504) 739-6531.
Very truly yours, l.
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pW R.F. Burski Director Nuclear Safety RFB/CJT/ssf Attachment cc:
J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9311'1'50'jif h31112 F
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. Attachment to W3F1-93-0198 Page'l of 4 l
ATTACHMENT l-1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
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APPENDIX A 0F INSPECTION REPORT 93-30 VIOLATION N0. 9330-01 Technical Specification 6.8.1, requires that written procedures be established, implemented, and maintained covering the activities referenced 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.
1.
Procedure HP-002-704, Rev. 4, " Personnel Decontamination," Step 10.1.2.3.A, states, "That for cases of skin contamination of the i
facial area,...take or instruct the individual to take, nasal wipes of each nostril using cotton-tipped swabs."
Contrary to the above, no nasal wipes were obtained from individuals who were' identified as having facial contamination on September 25, 1992, and on July 29, 1993.
2.
Procedure HP-002-704, Rev. 4, " Personnel Decontamination, " Step 10.1.2.6, states, in part, " Skin / clothing contamination is considered no longer present as evidenced by <100 cpm / probe area by direct frisk... When this limit can be met, then the individual can be i
rel e ased. "
Contrary to the above, final surveys conducted of individuals with i
skin contamination on February 19, 1992, and July 29, 1993, reported i
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 j
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
- j resurveyed after attempting decontamination.
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Page 2 of.4 j
Contrary to the-above, the dates and times that resurveys were conducted following decontamination of individuals were not denoted on July 23, 1993, and on February 17, 1992.
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RESPONSE
l (1)
Reason for the Violation i
Entergy Operations, Inc. admits this violation and believes that the root cause was personnel error in that both initiators'and reviewers of Skin Decontamination Reports failed to adhere to the requirements of Procedure HP-002-704.
t A potential contributing cause of this violation is that Procedure i
HP-002-704 is difficult to use.
Specifically, the procedure contains i
human factor weaknesses relating to procedure clarity and Skin Decontamination Report format.
(2)
Corrective Steps That Have Been Taken and the Results Achieved The cited failures to implement Procedure HP-002-704 involved five i
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 reconstructed, two presumptions are viable based on other data I
within the report.
First, the resurveys were taken on the date i
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),
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, q
I 1992, as "<1000."
Consequently, the report indicates the individual may have been released with skin' contamination l
greater 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 1
recorded "<1000" which would have been appropriate when counting a smear. The technician failed to correctly use cpm e
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Attachment to 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 indicate the proper units.
3.
Report 92-49 failed to denote the date and times of resurveys following decontamination of an individual on September 25, 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.
Although specific survey times cannot be reconstructed, it can be concluded that the surveys were taken on the date of occurrence. The individual did receive a whole-body count as required.
i 4.
Report 93-8 reported the final survey of residual contamination of an individual following decontamination on July 29, 1993, as
"<1000 dpm."
Consequently, the report indicates the individual l
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 decontaminated to <100 cpm / probe area. Apparently, the l
technician erroneously recorded "<1000 dpm" which would have 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 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 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, t.he 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 face), indicate that no consequential exposure occurred.
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t Attachment to W3F1-93-0198 Page 4 of 4' A review of other Skin Decontamination Reports generated since.
January 1,1992, was conducted to identify similar conditions.
1 Similar discrepancies were found on a number of reports.
The most frequent discrepancy identified was no dates and times for surveys.
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The discrepancies noted were evaporative and therefore non-correctable, r
The discrepancies noted involved a large percentage of the Radiation Protection staff. As a result, Radiation Protection management discussed this event and procedure compliance expectations with the Radiation Protection staff.
(3)
Corrective Steps Which Will Be fp n to Avoid Further Violations Procedure HP-002-704 will be evaluated for human factoring
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enhancements and revised as appropriate.
Included in this revision wtll be resolution of current procedure inconsistencies regarding
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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 Full compliance will be achieved by December 30, 1993.
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