ML20076D764

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Responds to NRC Re Violations Noted in Insp Rept 50-458/91-13 & Forwards Payment of Civil Penalty in Amount of $37,500.Corrective Actions:Each Operating Shift Documents That Radiation Survey Maps Reviewed
ML20076D764
Person / Time
Site: River Bend 
Issue date: 07/19/1991
From: Deddens J
GULF STATES UTILITIES CO.
To:
NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-35-335, NUDOCS 9107300209
Download: ML20076D764 (5)


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GULF STATES UTILITIES COMPANY

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1, U.S. Nuclear Regulatory Ccumission Docunent Control Desk ATTN:

D.t. rector, Office of Enforcenent Washington, D.C. 20555 Centlenent River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/91-13 Pursuant to 10 CFR 2.201, this letter provides Gulf States Utilities Ccupany's (GSU) response to the Notice of Violation for hTC Inspection Report No.

50-458/91-13.

The inspection related to activities authorized by hTC Operating License NPF-47 for River Bend Station Unit 1 (RBS).

GSU's reply to the violations is provided in the attachnents. Also enclosed is a check for $37,500.00 in payment of the inposed civil penalty.

Should you have any questions or care to discuss these matters, please contact l's. L. A. England at (504) 381-4145.

Sincerely,

/J.C. Deddons Senior Vice President

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'F C' cc: Regional Mninistrator q2 U.S. Nuclear Regulatory Ccrmission MS Region IV 611 Ryan Plaza Drive, Suite 1000 p

Arlington, TX 76011 oe esc NRC Resident Inspector P.O. Box 1051 J EC[

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NUCLEAR REGULATORY COMMISSION-STATE OF LOUISIANA

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PARISH OF WEST FELICIANA

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Docket No. 50-458 In~the Matter of

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GULF STATES UTILITIES COMPANY

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(River' Bend Station - Unit 1)

AFFIDAVIT J.

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Deddens, being _ duly sworn,_ states that he is a Senior Vice President of Gulf States Utilities Company; that he is authorized on-the part of said company to sign and file with the Nuclear.-Regulatory Commission the documents attached

' hereto; and 'that' all such documents are true and correct to the best of'his-knowledge, information and belief.

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J. C/Weddens L

Subscribed and-sworn to.before me,'a: Notary Public in and for the-Stato and Parish above named, this / 9b day of L

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3 EMy Commission expires with Life.

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L 7, Claudia-F. Hurst l

Notary Public in and for l

West Feliciana Parish, Louisiana L

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  1. 1TA 09 6fr REPIX '!D N3 RICE OF VIGATIGi 50-458/91-13 IEVEL III i<r2ndMCBS Notice of Violation - Intter frun R.D. Martin to J.C.

Deddens, dated 4

June 19, 1991.

-Enforcement Conference meeting stmmary - Letter frun S.J. Collina to

J.C. Deddens,-dated June 10, 1991, t

Inspection A. port No. 50-458/91-13 letter frm S.J.

Collins to J.C. Doddens, dated May 17, 1991.

t VIOIATION t

A. - Technical Specification 6.12.1 states, in part, that in lieu of the

" control device" or "" alarm signal" required by 10 CPR 20.203(c) (2),

each _high radiation area in which the-intensity of radiation is greater than 100 mrm/ hour but less than 1000 mrm/ hour shall be

' barricaded'and conspicuously y:sted as' a high radiation area, 1.

Contrary to t.he above, on April 1,

1991, the residual heat removal "A"

pump ' room, a high radiation area in which the intensity of radiation was greater than 100 mrem / hour but less

-then 1000 mrem / hour, was not-barricaded and conspicuously posted as a high-radiation area.

Specifically,- licensee radiation protection personnel discovered that a rope barrier had been Im oved during a surveillance test on the same date and had not been replaced.

2.

Contrary-to-the'above, on April 28,-1991, the lower elevation of the cask wash-down area in the fuel building, a high radiation _ area in.which the-intensity. of radiation was greater than 100 mrem / hour but less than'11000 mrem / hour, wasJ not barricaded.

Specifically, licensee radiation _ protection personnel discovered that a' rcpe barrier to this high radiation -

area had been moved,: leaving a portion of the entrance to this area unbarricaded.

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B. 1 Technical Specification 6.8.1 states, in_ part, that written procedures shalli be-established, implemented and maintained-covering, in part, the applicable procedures reccmnended in Appendix l

A of. Regulatory Guide 1.33, Revision 2, February;1978.

Append.ix A of Regulatory. Guide 1.33, Revision 2,

cites, among:

- activities that should be covered by written procedures, " Access' TControl sto-Radiation Areas Including a Radiaticri ~ Work Permit

. System."

- Iage 1 of -3 l

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4 IES pitcodure RSP-0200, " Radiation Work Permits," Revision 6, dated September 20, 1990, states, in part, that each worker assunes certain responsibilities for mintaining their exposure "As Iow As Ibasonably Achievable" and cites specific responsibilities as "cmplying with the requituments and instructions given on the IkP,"

and "being knowledgeable of the current radiological condit.4ons at their job site."

The special conditions and requirenents section of IES Radiation Work Permits states, in part, that " personnel are to review routi e survey books and/or Ih? addendum sheets so as to understand radiological conditions in their work area."

Contrary to the above, on April 24, 1991, NIC inspectors observed at least three workers entering arcan governed by Radiation Work Permits who did not review routine survey books and/cc Ih? addendum cheets which are naintained at the entrance to the areas and, therefore, did not understand or becme knowledgeable of the current radiological conditions at their job sites.

GSU RESPONSE GSU admits to the above violations.

REASONS FOR THE VIOIATION The cause of the violation was failure by sain GSU and contractor anployees to adhere to radiological program procedures.

CORRICTIVE STEPS WHIGI HAVE BEEN TAKEN AND THE RESULTS ACHIEED At the time of the two violations reganling high radiu ton area boundaries, a multifaceted corrective action program was in p ogress to correct already identified problems. These actions were documented in l

GSU Licenseo Event Reports LER 91-006 and LER 91-009 and in GSU's respnse to the Notice of Violation in Inspection Report 90-29 dated l

January 28, 1991.

A tack force had been formed in Decysnber 1990, to l

address the high radiation area boundary violation problem and tha l

resulting reconmendations were being implanented.

As stated in the letter transmitting the Notice of Violation, these corrective actions

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included such things as replacing rope barriers with lockable barriers, l

a retesting program of personnel on high radiation area controls and technical specification requirements emd extensive mnaganent involvatent 4.n camunicating to employees the significance of the problan.

Additionally, the anployees involved in these two violations received varying levels of discipline.

l As a result of the violation regarding anployees' failure to make themselves aware of radiological conditions in the work area the following additional actims were taken Page 2 of 3

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- Personnel have been verbally notified through neetings of their responsibility to make themselves aware of radiological conditions in the radiologically controlled area (RCA).

Each operations shift now docments that they have reviewed the radiation survey maps and are aware of conditions in the RCA.

- Radiation Protection technicians are now discussing rv.ological conditions with persons prior to entering the RCA to ensure that they are aware of radiological conditions in their work area.

Mditional infonstional postings will be placed in the plant to enhance enployee awareness of radiological conditions.

(I)RRECTIVE STEPS hWICH WILL BE TAKEN TO inOID FURTHER VIOIATIONS Continued emphasis and vigilance by GSU management to ranind and notivate the s taf f will ccmprise the r.ujor part of the ongoing correct bre action. These violations are Lidicative of poor performance by a snall nmber of sployees. Continued reinforcement by nanagment will be utilized as necessary.

DATE hEEN FULL (INPLIANCE WILL BE ACHIEVED Full ccupliance has been achieved in the area of high radiation area boundary requirments. The cumulatis-e corrective action and discipline has ccar to fruition and resulted in a heightened awareness in the staff that should prevent further problems.

'Ihe placenent of additional informational postings in the RCA will be ccmpleted by September 30, 1991.

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