ML20105B777

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-382/92-21.Corrective Actions:Containment Area Boundary Ropes Were Secured & Verified to Demarcate Clearly Correct Area & Event to Be Discussed W/Health Physics Personnel

ML20105B777
Person / Time
Site:	Waterford
Issue date:	09/16/1992
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-92-0412, W3F1-92-412, NUDOCS 9209210179
Download: ML20105B777 (2)

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R. F. Durskt W3F1-92-0412 A4.05 QA September 16, 1992 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 92-21 Reply to Notice of Violation Gentlemen:

J In accordance with 10CF R2.201, 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 cor.cerning this response, please contact C.J. Thomas at (501) 739-6531.

Very truly yours, wm RFB/CJT/ssf Attachment ec:

J.L. hlithoan, NRC Region IV D.L. Wigginton, NRC-NRR R.B. hicGehee N.S. Keynolds NRC Resident Inspectors Office

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9209210179 920916 PDR ADOCK 05000382 o

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W3F1-92-0412

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i ENTERGY OPER ATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN l

APPENDIX A OF INSPECTION REPORT 92-21

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VIOLATION NO. 9221-01 i

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Technical Specification G.8.1 requires, in part, that written procedures be i

established, implemented, and maintained covering the activities referenced in Appendi:c A of Regulatory Guide 1.33,' Revision 2, Febre.ary 1978.

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Section 7.e.(4) of Appendix A of Regulatory Guide 1.33, Revision 2, February l

j 1978 lists radiation protection procedures for contamination control.

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Section 5.2.2.2 of Administrative Procedure HP-001-210, " Radiological Posting l

Requirements," requires that contamination area postings be clearly demarcated l

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with the appropriate boundary ropes / ribbon, signs, and stanchions as necessary t

to control the activity.

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l Contrary to the above, on July 28, 1992, the inspector determined that the boundary roi 3s for a contaminated area posting in Safeguards Room A had fallen _

j down and, therefore, did not clearly demarcate the contaminated area.

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l R ESPONSE

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Reason for the Violation l

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Entergy Operations, Inc. admits this violation and believes that the root i

causo was inappropriate action in that two pieces of rope demarcating a

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contaminated area posting in Safeguards Room A were not appropriately connected. The two pieces of rope were taped end to end in a butt l'

wnnection. It is believed that tensional forces caused the ropes to l

separate and fall to the floor. The exact time of failure could not be determined; however, the area had been inupected and found satisfactory i

by a llealth Physics Technician on July 27,'1992.- Because the boundary l

copes were on the floor, they did not demarcate clearly the contaminated O

area.

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Corrective Steps That Have Been Taken and the Results Achieved i

Inmediately upon discovery of this event, the contaminated area boundary ropes were secured and verified to demarcate clearly the' correct area.

f Additionall,", Health Physics personnel performed an inspection _of other_

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i contaminated areas to identify similar conditions that could potentially lead j

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to downed boundaries. During this inspection, similar conditions were E

identified and corrected. N'o instancas of downed contaminated aren j

i boundaries were identified.

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. Attachment to W3F1-92-0412

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Corrective Steps Which Will Be Taken to Avoid Further Violations

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This event will be discussed with the staff Health Physics technicians to l

necentuatu lessons learned and the importance of securing. contaminated l

l area boundaries. Moreover, Ilealth Physics will promulgate additional guidance regarding the use of tape when establishing contaminated area f

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boundaries.

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.; ate When Full Compliance Will Be Achieved f

l Full cor.ipliance will be achieved by December 4.1992.

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