ML20097G215
| ML20097G215 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/12/1992 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-92-0170, W3F1-92-170, NUDOCS 9206160380 | |
| Download: ML20097G215 (3) | |
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W3t< 'l-92-0170 A4.05 QA June 12, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject
-Watcrford 3 SES Docket No. 50-382 Lleense No. NPF-38 NRC Inspection Report 02-10 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the vhilation identified in Appendix A of the subject inspection Report.
If you have any questions concerning tl.is res})onse, please contact C.J. Thomas at (504) 739-G531.
Very truly yours, i
4414 RFB /CJT/ssf Atachment cc:
R,D. Martin, NitC Region IV D.L. Wigginion,.NRC-NRR R.B. McGeheo N.S. Reynolds NRC Resident inspectors Offico
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s Attachment to lo W3F1-92 0170 i
Page 1 of 2 ATTACllMENT 1 i
j ENTERGY OPERATIONS INC. RESPONSE TO Tile VIOLATION IDENTIFIED IN a
APPENDIX A OF INSPECTION HEPoltT 92-10 b
VIOLATION NO. 0210_-0_1 i
l Technical Specification 6.8.1 requires, hi part, that written procedures be J
cstablished, implemented, and maintained covering the activities referenced in l
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 7.e.(1) of Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 lists radiation protection procedures for access to radiation areas, including a radiation work permit system.
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Section 4.2.6 of Administrative Procedure UNT-005-022. "RCA Access Control,"
requires that radiation workers be responsible for reviewing and signing the a
d applicable radiation work permits.
Contrary to the above, on April 15 und 10,1992, the inspector determined that i
approximately 12 workers involved with unloading a transportation cask signed 1
Radiation Work Permit (92-80), which was the wrong permit and was not applicable to the work performed.
RESPONSE
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(1)
Ilf. son for tho Violation l
Enteagy Operations, Inc. admits this violation and believes that the root cause was inattention to detailin that 7 workers involved with unloading a i
transportation cask signed Radiation Work Permit (RWP) 92-80, which was f
not appropriate for the work being performed. The 7 workers woro staging -
i and preparing a transportation cask to allow shipment of irradiated incore instrumentation for burial. This work required minimum radiological controls and was planned to be accomplished under the standing RWPs.
Conversely, RWP 92-80 was prepared to cover the loading of the irradiated l
incore instrumentation into the transportation cask in a Zone 3 llot Particle Area. As such, the RWP Imposed radiological controls that were significantly more stringent than those imposed by the standing RWPs.
Because of the contrasting radiological controls and job descriptions, the workers should havo realized that RWP 92-80 was inappropriate for the work they were performing.
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A contributing cause of this event involves the !!ealth Physics Shift Control Technician (SCT). The SCT issued RWP 92-80 t.o the workers under the impression that the RWP was requested for review only. The SCT did not instruct the workors to u*lllre the RWP since he know that the RWP covered activ31es scheduled for a twr time. This impression is understandable _
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given that rtdiation worken.xtC n review RWPs well in advance of signing them, llowever, if the SCT h.4.4uestioned the workers regarding their-intent, then the event may have been prevented.
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Attachment to W3F1-02 0170 Pago 2 of 2 (2)
Corrective Steps That llave !!oen Taken and the Results Achieved hnmediately upon discovery of this event, llealth Physics lustructed tr..ae workers inappropriately using RWP 92-80 to exit the Radir.tlon Controlled Area (RCA). These workers were instructed on the appropriate RWP and allowed to return to their work.
Additionally, llealth Physics individually briefed those workers still onsite-who inappropriately worked under RWP 92-80. These briefings were conducted to ensure worker understanding of this event and to accentuate lessons learned.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Vinlation_s Three specific actions are planned to prevent recurrence. First, General Employee Radiation Worker Training will be revised to emphasize the importance of using the proper RWP anti the possible consequences of using an incorrect RWP. In addition, radiation workers will be lustructed on their responsibilities and ac.tlons to be taken if the RWp provided for their work seems inappropriate.
Next, llealth Physics Procedures llP-001-110, "Radlation Work Permits,"
and ilPt001-101, "ALARA Program Implomontation," will be revised to require Employee Authorization whenever a RWP pre-job brief is required.
These revisions will prevent radiation workers from logging into the llP computer at the RCA control point unless they have received the required 4
pre-job brief. Finally, this event will be discussed with llealth Physics personnel as part of the Continuing Training Cycle.
(4)
Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 14, 1992.
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