ML20063K748
| ML20063K748 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/14/1994 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-94-0016, W3F1-94-16, NUDOCS 9403020087 | |
| Download: ML20063K748 (5) | |
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G na LA 70006 I d 502 709 6774 t
R. F. Durski r
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wo W3F1-94-0016 A4.05 PR February 14, 1994 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 NRC Inspection Report 93-34 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment I 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, 4
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l irector Nuclear Safety
'FB/CJT/ssf
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.ttachment cc:
L.J. Callan (NRC Region IV). D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9403020087 940214
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PDR ADOCK 050003B2 U
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Attachment to W3F1-94-0016 Page 1 of 3 ATTACHMENT 1 i
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 93-34 VIOLATION NO. 9334-02 L
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
j
. 1 Section 7.e(l) of Appendix A of Regulatory Guide 133 lists access to radiation areas and the implementation of an ALARA program as activities to be covered by radiation protection procedures.
l-Section 4.11.5 of Administrative procedure HP-001-101, Revision 9, "ALARA Program Implementation," requires that individual employees be responsible for reading, understanding, and signing the Radiation Work Permit (RWP) and strictly adhering to RWP instructions and requirements.
Standing RWP 93000007 required that health physics personnel be contacted prior to entering radiological restricted areas. The overheads of the radiation controlled area were posted as a radiological restricted area at the entrance to the radiation controlled area.
I i
l Contrary to the above, on November 23, 1993, a maintenance technician made-1 l
entries into the overhead on the +46 foot level of the' radiation controlled l
area without contacting health physics personnel prior to making 'the entries.
RESPONSE
(1)
Reason for the Violation i
Entergy Operations, Inc. admits this violation and believes that' the root cause was inappropriate action in that the maintenance technician assumed incorrectly that the overhead on the +46 foot level of the radiation controlled area (RCA) was an unrestricted area.
Although the +46 foot level of the RCA is generally clean, Radiation Protection (RP) has recognized that the internals of ventilation filter housings and duct work in the area may become contaminated.
As a result, the overheads (defined as greater than eight feet from the floor) in that area have been designated radiological restricted areas.
Furthermore, all overheads in'the RCA U
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W3F1-94-0016 Page 2 of 3 are designated radiological restricted areas and administrative controls have been established that require workers to contact RP prior to entering those areas.
Thus, the maintenance technician acted inappropriately in that he violated administrative controls the i
i two times he entered the overhead without first contacting RP.
A contributing cause of this event is poor communication. 'An RP technician at the scene observed the maintenance technician when he first entered the overhead. However, after noting the infraction, the RP technician did not clearly communicate that the overhead is a h
l radiological restricted area and that RP should be contacted prior _to entry.
Consequently, the maintenance technician did not contact RP prior to entering the area a second time. Moreover, the RP l
technician was not present to observe the second entry due to other responsibilities in the area.
If the RP technician had clearly-communicated the concern to the maintenance technician, then the second inappropriate entry may have been prevented.
(2)
Corrective Steps That Have Been Taken and the Results Achieved j
On November 23, 1993, the RP technician performed a survey to determine the contamination levels in the overhead. Survey results show that the overhead was radiologically clean at that time (e.g.,
loose contamination levels were less than 1,000 dpm/100 cm2 and fixed contamination levels were less than 2 mrem /hr).
The maintenance technician was counseled in accordance with the i
l Improving Human Performance Program.
RP and Maintenance conducted a j
l post job briefing to determine the consequences of this event.
No contamination concerns were identified. Additionally, this event was
~
discussed with Mechanical Maintenance personnel at the December safety meeting.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations-i Three corrective steps will be taken to avoid further. violations.
First, discussions will be held with RP personnel to accentuate this.
event and to remind them to assess the radiological consequences of overhead areas before granting workers entry. Second, RP will post additional signs for entering overheads in the RCA.
Finally, this i
l event will be discussed during the February site wide safety meetings to accentuate lessons learned.
l
Attachment to W3F1-94-0016 Page 3 of 3
- (4) ' bate When Full Compliance Will Be Achieved Full compliance will be achieved by February 28, 1994.
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For Regulatory Correscondence Only
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TO BE COMPLETED BY THE ORIGINATOR
..Pohev & Directives Coorainotor M///
- 1. This document centoins comm:tments
..Quchty Assurance Manager
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.. Operational Experience Engineering Mgr.
C No T.J. Gaudet DR iVN/f/h
. Training Manager
- 2. This document will cause o enange to
. 0cerations Training Supervisor the FSAR
.. Simulator Training Supervisor O Yes, License Document Chonge Reauest completed
..Mointenance Training Supervisor g No
.eischn: cat Training SuDervisor
- 3. This document recuires validation
..Engrg. Training & Accted. Supervise' in accordance with w4 802 i
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Return to:
C.J. Thomas OR C'.9/FN /
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- 9h(r Jeff Thomas #6531 D.E. MarDe DR th M Y i ACR ACilON RE QUESTED DE DOCUMENT REVIEW $1 SIGNATURE ILN - INCOMING LOG NUMBER AC AC flO N FI FILE CC COPY REQUIRED AP APPROV AL IN FOR INFORM ATION DOCNO DOCUMENT NUMBER CD - C ROSS DISCIPLINE REVIEW OR - ORtGIN ATOR DOCDATE DOCUMENT D ATE Rev. Date 2'io2
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