ML20073S810
| ML20073S810 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/05/1994 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-94-0090, W3F1-94-90, NUDOCS 9407060240 | |
| Download: ML20073S810 (4) | |
Text
_
'::= ENTERGY f"?"" "~ " " *' '"'
14U R. F. Bur ski h
w.
a W3F1-94-0090 A4.05 PR July 5, 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 94-08 Reply to Notice of Violation Gentlemen:
In acc,rdance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachhent 1 ths response to the violation identified in Appendix A of the subject inspection Report.
if you have any questions concerning this response, please contact D.F. Litolff at (504) 739-6693.
Very-truly yours, gu R.F. Bu ski Director Nuclear Safety RFB/DFL/tjs i
Attachment cc:
L.J. Callan (NRC Region IV), D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 0 L v." l gsR7 285$8 oS8?;l{g2.
f6DI'
Attachment to W3F1-94-0090 Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IQiNTIFIED IN APPENDIX A 0F INSPECTION. REPORT 94-08 VIOLATION N0. 9408-01 During an NRC inspection conducted on March 6 through April 16, 1994, one violation of NRC requirements was identified.
in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7, lists access control to radiation areas, including radiation wo-k permits, as activities to be covered by procedures.
Step 4.7 of Procedure HP-001-110 Revision 13. " Radiation Work Permits," states, in part, that individuals working under a radiation-work permit are responsible for reviewing the radiation work permit and observing and abiding by the radiation work permit and the radiological signs posted within the radiologically controlled area.
Contrary to the above, a conbinment airlock door operator entered into and worked in a posted contaminated area without a full set of protective clothing as required by the applicable radiation work permit.
This is a Severity Level IV violation (Supplement IV)_ (382/9408-01).
RESPONSE
(1)
Reason for the Violation Eatergy Operations Inc. adriits this violation and believes that the root cause was inadequate attention to details in that the containment airlock door operator failed to recognize the postings which designated the area in which he was working as a contaminated
i Attachment to W3F1-94-0090 Page 2 of 3 area. Hence the operator failed to fulfill the requirement of i
donning full protective clothing as stated in the applicable radiation work permit (RWP 1994-6037).
It should be noted that the individual had operated the containment airlock door prior to the date of the violation, but was not required to wear full protective clothing during these shifts because at that time the area was not posted as contaminated. The applicable rajiation work pern.it stated that protective clothing was required only in posted contaminated areas.
On the date of the violation, however, due to the process of destaging containment for preparation of entering Mod: ' Olot Shutdown), the containment airlock door area was posted as a ontaminated area.
The door operator, accustomed to working in the area without protective clothing, failed to recognize i
the change in postings and entered the area without the required protective clothing.
Entergy Operations, Inc. also admits that ineffective communica: Mn between Waterford 3 radiation protection (RP) personnel prevented the violation from being resolved imme'diately.
Prior to entering the containment building on April 12, 1994, during Refuel Outage 6, a radiation protection technician, accompanied by a NRC inspector, noted a containment airlock door operator not waring i
rubber gloves while in a contaminated area.
The operator was wearing street pants, shoe covers and a modesty shirt. The radiation protection technician directed the individual to exit the i
contaminated area and don rubber gloves prior to continuing work activities in the contaminated area.
The RP technician then contacted the RP office to inform RP personnel of the individual's failure to be properly dressed. The individual reentered the contaminated area with only shoe covers and rubber gloves as protective clothing.
After exiting the containment building, the inspector noticed that the applicable RWP required full protective clothing for workers in posted contaminated areas and brought this l
fact to the attention of the RP personnel.
Immediate actions were taken to correct the problem.
Radiation Protection personnel did not follow up to er.sure that the airlock door operator was properly dressed prior to reentering the area. They presumed that the matter had been adequately resolved when the field radiation protection technician first discovered the airlock door operator being improperly dressed. At the same time, the RP technician presumed that RP personnel would assure that the
Attachment to W3F1-94-0090 Page 3 of 3 individual was dressed properly after being directed to leave the-contaminated area. More effective communication between the RP field technician and RP office personnel to ensure that the R4P protective clothing requirements had been met would have resulted in a more immediate resolution of the problem.
(2)
Corrective Steps That Have Been Taken and the Results Achieved Upon notification by the NRC inspector that the airlock door operator was in a posted contaminated area without full protective clothing, RP personnel immediately. removed the individual from the area. The individual was then verbally counselled on the issue of adhering to RWP requirements.
Condition Report 94-366 was initiated to begin the corrective action process.
(3)
Corrective Steps Which Will Be Taken To Avoid Further Violations To help increase awareness and avoid such violations in the future, training sessions have been scheduled for RP personnel for the next cycle of continuing training. The training will include discussions of this violation and focus on communication and the ob arvation of worker performance.
(4)
Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance when the RP training mentioned above is complete. The scheduled completion date of this~ training is October 14, 1994.
_ _ _ _ _ _ _ _ _ _ _ _ _