IR 05000313/1992011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/92-11 & 50-368/92-11

ML20126C449
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/15/1992
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Yelverton J ENTERGY OPERATIONS, INC.
References
NUDOCS 9212230070
Download: ML20126C449 (5)

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NUCLEAR REGUI.ATORY COMMISSION

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Docket Nos. 50-313

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50-368 License Nos. DPR-51 NPF-6 J Entergy Operations, In ATTN: J. W. Yelverton, Vice President 1 Operations, Arkansas Nuclear One Route 3, Box 137G Russellville, Arkansas 72801 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NO. 50-313/92-11; 50-368/92-11 (NOTICE OF VIOLATION)

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Thank you for your letter, dated December 7, 1992, in response to our letter, dated November 25, 199 We have no further questions at this time and will review your .arrective actions during a future inspectio

Sincerely,

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A. Bill Beach, it ct r DivisionofRea.orPo')ects cc: ,

Entergy Operations, In !

ATTN: Donald C. Hintz, President &

Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286 Entergy Operations, In ATTN: John R. McGaha, Vice President Operations Support P.O. Box 31995 Jackson, Mississippi 39286

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Entergy Operations, In i

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Wise, Carter, Child & Caraway l

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ATTN: Robert B. McGehee, Es !

P.O. Box 651 Jackson, Mississippi 39205

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Entergy Operations, Inc.

ATTN: R. A. Fenech, General Manager Plant Operations Route 3, Box 137G Russellville, Arkansas 72801

Entergy Operations, Inc.

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ATTN: James J. Fisicaro 1 Director, licensing i Route 3, Box 137G i

Russellville, Arkansas 72801 Honorable Joe W. Phillips

. County Judge of Pope County

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Pope County Courthouse Russellville, Arkansas 72801 l Winston & Strawn

ATTN: Nicholas S. Reynolds, Esq.

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1400 L Street, Washington, Arkansas Department of Health

, ATTN: Ms. Greta Dieus, Director Division of Radiation Control and Emergency Management 4815 West Markham Street Little Rock, Arkansas 72201-3867 B&W Nuclear Technologies ATTN: Robert B. Borsum Licensing Representative-1700 Rockville Pike, Suite 525

- Rockville,-Maryland 20852 Admiral Kinnaird R. McKee, USN (Ret)

214 South Morris Street Oxford, Maryland 21654

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Entergy Operations, In ABB Combustion Engineering Nuclear Power ATTN: Charles B. Brinkman Manager, Washington Nuclear Operations

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12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852

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Entergy Operations, In DEC I 51992 l

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J. L. Milhoan Resident Inspector DRP Section Chief (DRP/A)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Section Chief (DRP\TSS) DRS G. F. Sanborn, E0 J. Lieberman, OE, MS: 7-H-5

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December 7, 1992 , 'E E 'l l

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OCAN129204 DEC 1 1 P "

I U. S. Nuclear Regulatory Commission *

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I Document Control Desk ' -- J'

l Mail Station P1-137 i Washington, DC 20555 Subject: Arkansas Nuclear One - Units 1 and 2

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Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 il Supplemental Response to Inspection Report 50-313/92-11; 50-368/92-11

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Gentlemen

Pursuant to the provisions of 10CFR2.201, attached is the j supplemental response requested in a letter from Mr. Bill Beach dated November 25, 1992, to the violation identified during the inspection of activities associated with the

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failure to follow the instructions contained in Radiation Work Permits.

Our assessment of the' nature of these deficiencies indicates

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that broader improvements are needed in this area. We are

taking actions to improve performance including hands-on i radiation worker training and communicating expectations to line-management regarding the importance of being actively

involved to monitor the performance of their personnel and

ensure that individual radiological practices are being properly implemented. Special emphasis by ANO executive management has been placed on improvements in radiological

work practice The corrective actions currently in progress are designed to improve radiation worker practices. We are committedoto

ensure that ANO's radiological work practices meet all regulatory requirements and Entergy Operations' standards of

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excellenc Should you have questions or. comments, please call me at 501-964-860 Very truly yours, nw NM James . Fisicaro

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U. S. NRC December 7, 1992

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Page 2 cc: Mr. James L. M11hoan U. S. Nuclear Regulatory Commission Region IV l 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. Thomas W. Alexion NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike l Rockville, Maryland 20852 Mr. Roby B. Bevan, Jr NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852

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. Attachmont to OCAN129204 Page 1 NOTICE OP VIOLATION

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Unit 1 Technical Specification 6.8.1.a required, in part, that

" Written procedures shall be established, implemented and i

maintained covering ... the applicable procedures recommended in l 1 Appendix A of Regulatory Guide 1.33, November, 1972." Safety Guide 33, Appendix A, recommended that personnel monitoring and radiation work permits be covered by written procedure Procedure 1000.031, Revision 15, " Radiation Protection Manual,"

required that " Radiologically controlled areas at Arkansas

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Nuclear One are identified with yellow and magenta (purple)

ropes, flags, posting signs, tape, etc. which shall not be used for any other purpos All personnel are required to adhere to these postings."

Similarly, Unit 2 Technical Specification, 6.8.1.a. required, in part, that " Written procedures shall be established, implemented and maintained covering ... the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February

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1978." Regulatory Guide 1.33, Appendix A, recommended that radiation work permits be covered by written procedure Procedure 1000.031, Revision 15, " Radiation Protection Manual,"

required that " individuals are responsible for ... adherence to radiological protection requirements ..." and "... being knowledgeable of and understanding the requirements and contents of the Radiological Work Permit (RWP) under which work will.be performed."

Radiation Work Permit 920993, Revision 1, required workers to perform a whole body frisk when exiting a radioactive material are Radiation Work Permit 921438, Revision 1, required workers to wear surgical gloves for electrical penetration work within a radioactive materials area.

I contrary to the above, the following three examples of failure to follow radiation work permit requirements were identified:

, On August 26, 1992, an operator and an escorted visitor failed to adhere to a radiological posting for a radioactive mctorials area, which ir.dicated a radiation work permit and contamination monitoring was required for entr On September 4, 1992, the resident inspector observed that two main steam safety valve workers failed to

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perform whole body frisks when exiting a radioactive material area as required by Radiological Work Permit 920993, Revision On September 8, 1992, the resident inspector observed that two Electrical Penetration 2E-22 workers failed to wear surgical gloves when performing work within a radioactive materials area as required by Radiological Work Permit 921438, Revision These three examples constitute one Severity Level IV violatio (supplement IV) (313/9211-02; 368/9211-03)

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OCAN129204 Pcgn 2

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Response to violation 313/9211-02; 368/9211-03

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(1) Reason for the violation:

Example A Cited example A was caused by a personnel error. The operator and escorted visitor were undergoing an operations license examination, and they did not recognize that the area they were entering was a posted radiologically controlled area (RCA). The RCA is also a security area and two (2) separate informational (radiation and security) postings are located on the access door. The unauthorized entry into the RCA was not detected until the escorted visitor noticed the rsdiation area posting as they egressed through the security doo Eyample B Cited example B was caused by a personnel error. The two (2)

main steam safety valve workers were aware that whole body frisking was required. They did not perform a whole body frisk before egressing the RCA because the portable frisker

was located in a poorly lighted area and was not readily visible to the workers. They exited the RCA and proceeded to a known frisker location where a successful whole body frisk was completed. Additionally, a common RCA ingress / egress point had not been established which would have placed the frisking equipment in a readily accessible are Example C Cited example C was caused by a personnel error. A crew of contract workers were pulling electrical cables into an electrical penetration device which caused frequent tearing of the surgical gloves. Additionally, the contract workers experienced difficulty in maintaining a grip on the cables due to excessive sweating in the gloves. Thus, the gloves were removed to get a better grip on the cable (2) Corrective steps taken and results achieved:

Example A The operator and escorted visitor self-reported the unauthorized entry into the RCA to the Health Physics (HP)

Departmen Immediate actions were taken by HP to assess radiation exposure to the individuals and contamination control measures in the area in question. Additionally, the operator and escorted visitor were counselled on the required radiological control requirement An evaluation of the relationship between radiological control barriers and other barriers, i.e., security and fire doors, was performed to determine if additional improvements in identification of radiological control barriers are necessar The results indicated that current postings and warnings are in compliance with governing document _

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Attechmont to OCAN129204 Pago 3 T'his incident was discussed with Arkansas Nuclear One (ANO)

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Unit One Operations personnel and radiological control requirements reemphasized during operations rotational requalification training. This was completed on November 6, 199 Example B The two (2) main steam safety valve workers were aware that whole body fricking was required. When the workers could not locate a frisker in the area in which they were working, they exited the RCA and proceeded to a known frisker location where a successful whole body frisk was completed. The frisker was relocated so that it is clearly visible and accessible, and the individuals involved were counselled on the required radiological control requirements for frisking prior to leaving the RC Strategic placement of friskers is critical especially when RCAs are established on a temporary or infrequent basi Personnel in such areas must be able to recognize where friskers are located. To assure the consistent placement of friskers in the most ideal locations, an evaluation of frisker placement practices was performed and a memorandum to Health Physics Technicians was issued on November 6, 1992, providing guidance on proper frisker placemen Example C

. Health Physics Department management and the electrical penetration worker's supervisor counseled the contract crews involved in the electrical penetration wor Emphasis was placed on reading and understanding the radiation work permit, complying with the instructions contained in the RWP, monitoring techniques and control of contamination method (3) Corrective steps which will be taken to prevent recurrence:

Example A Since this cited example was caused by a personnel error and corrective actions were completed, no specific corrective steps to prevent recurrence were identified; however, common corrective measures outlined on page 4 of this response were identifie Example B Since this cited example was caused by a personnel error and corrective actions were completed, no specific corrective steps to prevent recurrence were identified; however, common corrective measures outlined on page 4 of this response were identifie _ _ _ - - _ - _ _ _ - _ _ - _ _ _ - _ _ _ _ _ _ .

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OCAN129204 Pcgn 4

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Example C

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Since this cited example was caused by a personnel error

involving contract crews who are no longer working on site, no specific corrective steps to prevent recurrence were identified; however, common corrective measures outlined on page 4 of this response were identifie :

i Corrective Measures Common To All Three (3) Examples A memorandum issued on November 3, 1992, emphasized the requirement and need to have ANO supervision routinely monitor the performance of their personnel during work activities

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involving radiological hazards to ensure that proper radiological I work practices are being implemented. This oversight is important during periods in which HP coverage is not required and I for job activities that are repetitive in nature or involve j extended periods of tim '

Two assessments were conducted during the weeks of September 21, j 1992 and November 16, 1992 to identify improvement areas of the I ANO radiological protection program and practice Both I assessments were based on Insticute of Nuclear Power Operation Objectives entitled " Radiological Protection Organization and Administration" and " General Employee Knowledge and Ability in Radiological Protection" und others. Based on the results of these assessments, several recommendations for improvements to

radiation work practices and the radiological protection program were identified. The following summarizes the key general areas requiring increased emphasis

Line management needs to be more actively involved in supporting implementation of the Radiological Protection l Program.

l l Better communication and training to radiation workers on l radiological work practice Enhance the radiological infraction reporting system for better reporting, trending and analysis.

Currently, a special radiation work practice training course has

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been developed and is being provided for ANO health physics, maintenance, selected on-site contractor radiation workers and

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management personnel. This training, conducted by health physics

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and training personnel, provides both basic and practical hands-

! on instruction in radiological work practices. This training began on November 23, 1992, and is expected to be completed by

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December 31, 1992.

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OCAN129204 Page 5 j

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'As a result of the detailed assessment results, the Vice

President, ANO Operations met directly with the affected plant management and supervisory staff to place special emphasis on i

expectations regarding radiological work practice These

discussions focused on cultural changes required to facilitate

' improving the implementation of the radiological protection ,

l program at ANO. This included individual ownership, self- I j checking, professionalism and more management involvement and j oversight at the department level. Applicable managers reviewed i the assessment results and developed specific action plans to j improve their performance within their area of responsibility

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under the radiological protection program. Further review of i individual department action plans is being performed by plant )

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! management to insure consistency and appropriate

. Inter-departmental plan integration. This integrated corrective l j action plan will be reviewed by December 15, 1992.

(4) Date when full compliance will be achieved:

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!- These three (3) examples-of failure to follow RWP instructions

did not cause any measurable increase in personnel exposures j nor resulted in any spread of contamination. Upon counselling i of the individuals involved, ANO was in compliance with its j radiological protection program.

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